HomeMy WebLinkAboutReports - 2023.09.14 - 40522
AGENDA ITEM: Acceptance from the State of Michigan of the FY 2022 Homeland Security Grant
Program
DEPARTMENT: Emergency Management & Homeland Security
MEETING: Board of Commissioners
DATE: Thursday, September 14, 2023 6:00 PM - Click to View Agenda
ITEM SUMMARY SHEET
COMMITTEE REPORT TO BOARD
Resolution #2023-3197
Motion to approve the attached Interlocal Agreement along with funding in the amount of
$791,232, authorize the Chair of the Board of Commissioners to execute the Agreement and all
other related documents between Macomb County and Oakland County; further, amend the FY
2024 budget as detailed in the attachment A.
ITEM CATEGORY SPONSORED BY
Grant Penny Luebs
INTRODUCTION AND BACKGROUND
The Fiscal Year 2022 Homeland Security Grant Program (HSGP) is one of three grant programs
that constitute the Department of Homeland Security (DHS) Federal Emergency Management
Agency’s (FEMA) focus on enhancing the ability of state, local, tribal, and territorial governments, as
well as nonprofits, to prevent, protect against, respond to, and recover from terrorist attacks. The
grant programs are part of a comprehensive set of measures authorized by Congress and
implemented by DHS to help strengthen the Nation’s communities against potential terrorist attacks.
The HSGP supports DHS’s goal to Strengthen National Preparedness and Resilience.
The three HSGP programs include: State Homeland Security Program (SHSP), Urban Area Security
Initiative (UASI), and Operation Stonegarden (OPSG).
Funding was released from the United States Department of Homeland Security, Federal
Emergency Management Agency (FEMA) to the State of Michigan for the 2022 Homeland Security
Grant Program (HSGP). The State of Michigan has awarded a 2022 Homeland Security Grant to
Region 2 which includes, but is not limited to, the City of Detroit and the counties of Macomb,
Monroe, Oakland, St. Clair, Washtenaw, and Wayne. The Michigan Homeland Protection Board
created Regional Homeland Security Planning Boards throughout the State to identify and prioritize
how the grant funds will be used. The Regional Homeland Security Planning Board for Region 2,
Urban Area Security Initiative (UASI) Board, is comprised of the representatives from the above-
listed political subdivisions. Macomb County voted and approved to act as the Fiduciary Agent and
Subgrantee for the Region 2 Homeland Security Planning Board for the fiscal year (FY) 2022
HSGP. Macomb County has entered into a grant agreement with the State of Michigan as the
subgrantee.
POLICY ANALYSIS
The Oakland County was awarded $36,254 from the State Homeland Security Program (SHSP),
$534,978 from the Urban Area Security Initiative (UASI) and $220,000 for regional projects for a
total award of $791,232, a decrease of $21,256 from the previous fiscal year. The regional funding
will continue two (2) Homeland Security – Regional SAP positions (#1060601–10296 and
#1060601-10520) and two (2) Special Revenue Intelligence Analyst positions in the Sheriff’s Office,
Emergency Response and Preparedness Division Admin Unit (#4030501-11083 and #4030501-
14715). The Oakland County Corporation Counsel has reviewed and approved the attached
Memorandum of Understanding (MOU) – Transfer/Acceptance of Equipment for all purchased
equipment by Oakland County to be used for the 2022 HSGP. The MOU will be signed every time a
piece of equipment is given to an Oakland County special response team or community to use
under the scope and intent of the grant. Corporation Counsel has reviewed and approved the Terms
of 2022 HSGP Funding document for all training, conferences or related expenses. The Terms of
2022 HSGP Funding will be signed by a special response team or community once a year for all
training, conference or related expenses funded by the grant. The MOU – Transfer of Equipment
and the Terms of 2022 HSGP Funding documents will be kept on file with the required grant
reimbursement paperwork within the Emergency Management Division.
The grant agreement has completed the Grant Review Process in accordance with the Board of
Commissioners Grant Procedures. Acceptance of this grant does not obligate the County to any
future commitment and continuation of the special revenue positions in the grant is contingent upon
future levels of grant funding.
BUDGET AMENDMENT REQUIRED: Yes
Committee members can contact Michael Andrews, Policy and Fiscal Analysis Supervisor at
248.425.5572 or andrewsmb@oakgov.com, or the department contact persons listed for additional
information.
CONTACT
Robert Seeley, Chief Emergency Management Public Services
ITEM REVIEW TRACKING
Aaron Snover, Board of Commissioners Created/Initiated - 9/14/2023
AGENDA DEADLINE: 09/14/2023 6:00 PM
ATTACHMENTS
1. EMHS_FY22_Homeland Security Grant Program. Sch A
2. Grant Review Sign-Off
3. 2022 Exhibit B -2022 Homeland Security Grant Agreement (2)
4. HSGP - Equipment MOU_2022_Final
5. 2022 Interlocal Agreement - Oakland (2)
6. 2022 Exhibit A -Fiduciary Appointment (2)
7. HSGP_Personnel Time Certification_LSchwan
8. Memo - 2022 Interlocal Oakland 7182023 analyst
9. MI FY 2022 HSGP FACT SHEET
10. fema_fy-2022-preparedness-grants-manual
11. FY22 HSGP NOFO_GPD Approved_clean 5_09_2022_508AB
COMMITTEE TRACKING
2023-09-05 Public Health & Safety - Recommend and Forward to Finance
2023-09-06 Finance - Recommend to Board
2023-09-14 Full Board - Adopt
Motioned by: Commissioner Penny Luebs
Seconded by: Commissioner Christine Long
Yes: David Woodward, Michael Spisz, Penny Luebs, Karen Joliat, Kristen Nelson, Christine
Long, Robert Hoffman, Philip Weipert, Gwen Markham, Angela Powell, Marcia Gershenson,
Janet Jackson, William Miller III, Yolanda Smith Charles, Charles Cavell, Ajay Raman (16)
No: None (0)
Abstain: None (0)
Absent: Brendan Johnson, Gary McGillivray, Michael Gingell (3)
Passed
Oakland County, Michigan
EMERGENCY MANAGEMENT AND HOMELAND SECURITY - 2022 HOMELAND SECURITY GRANT PROGRAM (HSGP) INTERLOCAL AGREEMENT
Schedule "A" DETAIL
R/E Fund Name Division Name
Fund #
(FND)
Cost Center
(CCN) #
Account #
(RC/SC)
Program #
(PRG)
Grant ID
(GRN) #
Project ID #
(PROJ)
Regio
n
(REG)
Budget
Fund
Affiliat
e (BFA)
Ledger
Account
Summary Account Title
FY 2023
Amendment
FY 2024
Amendment
FY 2025
Amendment
R Other Grants Homeland Security FND11011 CCN1110101 RC610313 PRG115125 GRN-1004157 610000 Federal Operating Grants $571,232 $571,232 $571,232
R Other Grants Sheriff FND11011 CCN4030501 RC610313 PRG110110 GRN-1004157 610000 Federal Operating Grants 220,000 220,000 220,000
Total Revenues $791,232 $791,232 $791,232
E Other Grants Homeland Security FND11011 CCN1110101 SC702010 PRG115125 GRN-1004157 702000 Salaries 133,912 133,912 133,912
E Other Grants Homeland Security FND11011 CCN1110101 SC722740 PRG115125 GRN-1004157 722000 Fringe Benefits 80,465 80,465 80,465
E Other Grants Homeland Security FND11011 CCN1110101 SC774636 PRG115125 GRN-1004157 770000 Info Tech Operations 5,600 5,600 5,600
E Other Grants Homeland Security FND11011 CCN1110101 SC750567 PRG115125 GRN-1004157 750000 Training-Educational Supplies 28,000 28,000 28,000
E Other Grants Homeland Security FND11011 CCN1110101 SC760126 PRG115125 GRN-1004157 760000 Capital Outlay Miscellaneous 349,466 349,466 349,466
E Other Grants Sheriff FND11011 CCN4030501 SC702010 PRG110110 GRN-1004157 702000 Salaries 142,432 142,432 142,432
E Other Grants Sheriff FND11011 CCN4030501 SC722740 PRG110110 GRN-1004157 722000 Fringe Benefits 51,357 51,357 51,357
Total Expenditures $791,232 $791,232 $791,232
R Other Grants Homeland Security FND11011 CCN1110101 RC610313 PRG115125 GRN-1004042 610000 Federal Operating Grants $(612,488)$-$-
R Other Grants Sheriff FND11011 CCN4030501 RC610313 PRG110110 GRN-1004042 610000 Federal Operating Grants (200,000)
Total Revenues $(812,488)$-$-
E Other Grants Homeland Security FND11011 CCN1110101 SC702010 PRG115125 GRN-1004042 702000 Salaries $(154,634)--
E Other Grants Homeland Security FND11011 CCN1110101 SC722740 PRG115125 GRN-1004042 722000 Fringe Benefits (88,376)--
E Other Grants Homeland Security FND11011 CCN1110101 SC774636 PRG115125 GRN-1004042 770000 Info Tech Operations (5,600)
E Other Grants Homeland Security FND11011 CCN1110101 SC750567 PRG115125 GRN-1004042 750000 Training-Educational Supplies (28,000)
E Other Grants Homeland Security FND11011 CCN1110101 SC760126 PRG115125 GRN-1004042 760000 Capital Outlay Miscellaneous (335,878)--
E Other Grants Sheriff FND11011 CCN4030501 SC702010 PRG110110 GRN-1004042 702000 Salaries (140,000)--
E Other Grants Sheriff FND11011 CCN4030501 SC722740 PRG110110 GRN-1004042 722000 Fringe Benefits (60,000)--
Total Expenditures $(812,488)$-$-
GRANT REVIEW SIGN-OFF – Emergency Management & Homeland Security Division
GRANT NAME: 2022 Homeland Security Grant Program (HSGP) Interlocal Agreement
FUNDING AGENCY: United States Department of Homeland Security, Federal Emergency Management Agency
(FEMA) Macomb County as Fiduciary
DEPARTMENT CONTACT: Robert Seeley/(248) 858-5080
STATUS: Grant Acceptance (Greater than $10,000)
DATE: 08/07/2023
Please be advised that the captioned grant materials have completed internal grant review. Below are the returned
comments.
The Board of Commissioners’ liaison committee resolution and grant acceptance package (which should include this sign-
off and the grant agreement/contract with related documentation) may be requested to be placed on the agenda(s) of the
appropriate Board of Commissioners’ committee(s) for grant acceptance by Board resolution.
DEPARTMENT REVIEW
Management and Budget:
Approved – Sheryl Johnson (07/31/2023)
Human Resources:
Approved - Heather Mason (07/27/2023)
Risk Management:
Approved. No Couty required insurance detailed – Robert Erlenbeck (07/27/2023)
Corporation Counsel:
Approved – Heather Lewis (08/06/2023)
OAKLAND COUNTY HOMELAND SECURITY DIVISION
MEMORANDUM OF UNDERSTANDING - TRANSFER/ACCEPTANCE OF EQUIPMENT
Page 1 of 3
Oakland County, by and through its Homeland Security Division, (hereinafter referred to as the Grantor), in accordance with Fiscal Year 2022 Homeland Security
Grant (Grant Program) is providing the below listed Equipment to _______________ (hereinafter referred to as the Subrecipient), DUNS # ______________. The
undersigned acknowledges acceptance of said Equipment and understands the following:
1. The original source of grant funding is the U.S. Department of Homeland Security, CFDA# 97.067, Federal Award #EMW-2022-SS-00031-S01. The funding is
passed through to the Grantor by the Michigan Department of State Police, Emergency Management and Homeland Security Division Grant and the County
of Macomb Grant # EMW-2022-SS-00021.
2. The federal award period is September 1, 2022 through May 31, 2025.
3. The purpose of the Federal funding is to support state and local efforts to prevent terrorism and other catastrophic events and to prepare the nation for
threats and hazards that pose the greatest risk to the security of the United States.
4. The value of Equipment provided to the Subrecipient is $ ______________.
5.
EQUIPMENT AMOUNT EQUIPMENT
VENDOR
PHYSICAL LOCATION
OF EQUIPMENT
24 HOUR CONTACT
(NAME & PHONE)
BUSINESS CONTACT
(NAME & PHONE)
6. By signing this Memorandum of Understanding, the Subrecipient accepts the Equipment in its current condition, “AS IS”, and acknowledges that it had an
opportunity to inspect the Equipment.
7. By signing this Memorandum of Understanding, the Subrecipient agrees to comply with the Office of Management and Budget (OMB) Uniform Administrative
Requirements, Cost Principles, and Audit Requirements (2 CFR Part 200). The Subrecipient receiving Equipment will be required to complete a risk assessment
and be subject to financial and program monitoring. Oakland County Fiscal Services will provide necessary information to Subrecipients for their single audit
reporting on a quarterly basis.
8. The Subrecipient acknowledges and agrees to comply with applicable provisions governing U.S. Department of Homeland Security (DHS) access to records,
accounts, documents, information, facilities, and staff. The Subrecipient also agrees to require any subrecipients, contractors, successors, transferees, and
assignees to acknowledge and comply with these same provisions. Detailed information on record provisions can be found in the DHS Standard
Administrative Terms and Conditions located at http://www.dhs.gov/publication/fy15-dhs-standard-terms-and-conditions, specifically in the DHS Specific
Acknowledgements and Assurances.
OAKLAND COUNTY HOMELAND SECURITY DIVISION
MEMORANDUM OF UNDERSTANDING - TRANSFER/ACCEPTANCE OF EQUIPMENT
Page 2 of 3
9. Upon execution of this Memorandum of Understanding the Subrecipient shall be solely responsible for the Equipment, including but not limited to, the
following:
9.1. Operation of the Equipment;
9.2. Maintenance and repair of the Equipment;
9.3. Replace or repair Equipment which is willfully or negligently lost, stolen, damaged, or destroyed;
9.4. Investigate, fully document, and make part of the official Grant Program records any loss, damage, or theft of Equipment;
9.5. Insurance for the Equipment if required by law or if the Subrecipient deems it appropriate in its discretion;
9.6. Training for use of the Equipment, if training is not included with the purchase of the Equipment; and
9.7. Liability for all claims arising out of the Subrecipient’s use of the Equipment.
10. The Subrecipient shall comply with and shall use the Equipment in accordance with the requirements in 44 CFR 13.32 – Equipment, and the 2019 Homeland
Security Grant Program Guidance for the above-referenced Grant.
11. The Subrecipient shall keep the Grantor informed of the location of the Equipment. If the Equipment by its nature is mobile, the Subrecipient must provide
a general location or “home-base” where the Equipment can be found. If the location of the Equipment changes, the Subrecipient shall provide the new
location to the Grantor immediately. The information required by this Section shall be provided to the Grantor upon execution of this Memorandum of
Understanding and continue until three (3) years after the close of this Grant Program. Except for items valued under $5,000 that are disposable or
expendable, the Subrecipient shall inform the Grantor if it plans to dispose and/or return the Equipment and work with the Grantor regarding any issues
associated with disposal/return of the Equipment.
12. Subrecipients receiving $750,000 or more in Federal funds in their fiscal year shall have a single audit performed in compliance with 2 CFR 200 Subpart F –
Audit Requirements. The Equipment included on this Memorandum of Understanding shall be included on the Schedule of Expenditures of Federal Awards
if the agency is required to have a single audit performed. Subrecipients must also submit a Corrective Action Plan for any audit findings that impact
Homeland Security funded programs and management letter (if issued) with a response. Subrecipients exempt from the Single Audit requirements that
receive less than $750,000 of total Federal funding must submit a Financial Statement Audit prepared in accordance with GAAS if the audit includes
disclosures that may negatively impact Homeland Security programs including, but not limited to fraud, financial statement misstatements, and violations
of contract and grant provisions.
13. The Subrecipient shall be solely responsible for all costs, fines, and fees associated with the use and misuse of the Equipment, including but not limited to,
costs for replacing the Equipment or costs, fines, or fees associated with an ineligible use determination by auditors.
14. The Subrecipient shall make the Equipment available to the Grantor and State and Federal Auditors upon request.
15. The Subrecipient shall make the Equipment available to all UASI regional partners subject to any user agreement or memorandum of understanding that may
be required by the Subrecipient.
OAKLAND COUNTY HOMELAND SECURITY DIVISION
MEMORANDUM OF UNDERSTANDING - TRANSFER/ACCEPTANCE OF EQUIPMENT
Page 3 of 3
The person acting for the Grantor in administering this equipment is:
Name: __________________________________________________
Location/Building: ________________________________________
Telephone No.: __________________________________________
Email Address: ___________________________________________
Organization: _______________________________________________________________________
Authorized Official:
Signature: _________________________________________________ Date: ____________________
Printed Name: ____________________________________________ Phone: ____________________
Email Address: _______________________________________________________________________
Financial Point of Contact:
Signature: _________________________________________________ Date: ____________________
Printed Name: ____________________________________________ Phone: ____________________
Email Address: _______________________________________________________________________
Approved By Oakland County Homeland Security:
Signature: _________________________________________________ Date: ____________________
Printed Name: ____________________________________________ Phone: ____________________
Title: ____________________________________________
Page 1
2022 Homeland Security Grant Program Funding Agreement – 04182023
2022 HOMELAND SECURITY GRANT PROGRAM
INTERLOCAL FUNDING AGREEMENT
BETWEEN
MACOMB COUNTY
AND
OAKLAND COUNTY
This Interlocal Funding Agreement ("the Agreement") is made between Macomb County, Michigan
Municipal Corporation, 1 S. Main, Mt. Clemens, MI 48043 ("Fiduciary”), and Oakland County, 1200
North Telegraph, Pontiac, MI 48341, a Michigan Municipal Corporation ("Political Subdivision"). In
this Agreement the Fiduciary and the Political Subdivision may also be referred to individually as
"Party" or jointly as "Parties."
PURPOSE OF AGREEMENT. Pursuant to the Urban Cooperation Act of 1967, 1967 PA 7, MCL
124.501, et seq., the Fiduciary and the Political Subdivision enter into this Agreement for the purpose of
passing through 2022 Homeland Security Grant Program (Grant Program) funds to the Political
Subdivision; delineating the relationship and responsibilities among the Fiduciary, the Political
Subdivision, and the Region 2 Planning Board regarding the Grant Program; and addressing use of
Grant Program funds, including but not limited to, the purchase, use, and tracking of equipment
purchased with Grant Program funds, purchase or reimbursement of services with Grant Program funds,
and/or reimbursement for certain salaries and/or overtime with Grant Program funds.
Macomb County, Michigan was elected and appointed Fiduciary for the 2022 Homeland Security Grant
Program by Region 2 Planning Board at its August 17, 2022, meeting.
Macomb County accepted the position of Fiduciary and as a result entered into the 2022 Homeland
Security Grant Program Agreement with the State of Michigan and became the Subgrantee for the Grant
Program.
In consideration of the mutual promises, obligations, representations, and assurances in this Agreement,
the Parties agree to the following:
1.DEFINITIONS. The following words and expressions used throughout this Agreement, whether
used in the singular or plural, within or without quotation marks, or possessive or nonpossessive,
shall be defined, read, and interpreted as follows.
1.1. Agreement means the terms and conditions of this Agreement, the Exhibits attached hereto,
and any other mutually agreed to written and executed modification, amendment, or
addendum.
1.2. Claim means any alleged loss, claim, complaint, demand for relief or damages, cause of
action, proceeding, judgment, deficiency, liability, penalty, fine, litigation, costs, and/or
expenses, including, but not limited to, reimbursement for attorney fees, witness fees, court
costs, investigation expenses, litigation expenses, and amounts paid in settlement, which are
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2022 Homeland Security Grant Program Funding Agreement – 04182023
imposed on, incurred by, or asserted against the Fiduciary or Political Subdivision, as defined
herein, whether such claim is brought in law or equity, tort, contract, or otherwise.
1.3. Day means any calendar day beginning at 12:00 a.m. and ending at 11:59 p.m.
1.4. Fiduciary means Macomb County, a Michigan Municipal Corporation including, but not
limited to, its Board, any and all of its departments, divisions, elected and appointed officials,
directors, board members, council members, commissioners, authorities, committees,
employees, agents, and/or any such persons successors.
1.5. Political Subdivision means a Michigan Municipal Corporation including, but not limited to,
it’s Council, Board, any and all of its departments, its divisions, elected and appointed
officials, directors, board members, council members, commissioners, authorities,
committees, employees, agents, subcontractors, attorneys, and/or any such person’s
successors.
1.6. Region means the area comprised of the City of Detroit and Macomb, Monroe, Oakland, St.
Clair, Washtenaw, and Wayne Counties. This Region mirrors the existing State emergency
management district and the Office of Public Health Preparedness bio-defense network
region.
1.7. Region 2 Homeland Security Planning Board (“Region 2 Planning Board”) means the
Regional Homeland Security Planning Board for Region 2, as created by the Michigan
Homeland Protection Board, and is comprised of the City of Detroit and Macomb, Monroe,
Oakland, St Clair, Washtenaw, and Wayne Counties. The Region mirrors the existing State
emergency management district and the Office of Public Health Preparedness bio-defense
network region.
1.8. 2022 Homeland Security Grant Program (“Grant Program”) means the grant program
described and explained in Exhibit B which began September 1, 2022 and ends May 31,
2025. The Grant Program is a primary funding mechanism, administered by the United
States Department of Homeland Security (DHS) and plays an important role in the
implementation of the National Preparedness System (NPS) by supporting the building,
sustainment, and delivery of core capabilities essential to achieving the National
Preparedness Goal (NPG) of a secure and resilient nation.
2.AGREEMENT EXHIBITS. The Exhibits listed below and their properly promulgated
amendments are incorporated and are part of this Agreement.
2.1. Exhibit A – Region 2 Homeland Security Planning Board meeting minutes from August 17,
2022; re: 2022 Homeland Security Grant Program Fiduciary;
2.2. Exhibit B – 2022 Homeland Security Grant Program Agreement between the Fiduciary and
the State;
3.FIDUCIARY RESPONSIBILITIES.
3.1. The Fiduciary shall comply with all requirements set forth in the Grant Program Agreement
between the Fiduciary and the State of Michigan, attached as Exhibit B.
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2022 Homeland Security Grant Program Funding Agreement – 04182023
3.2. The Fiduciary shall comply with all requirements set forth in the 2022 Homeland Security
Grant Program Guidance.
3.3. The Fiduciary shall submit all required project forms to the State for review and approval
which the Political Subdivision has submitted to the Fiduciary and been approved by the
Region 2 Homeland Security Planning Board.
3.4. The Fiduciary shall reimburse the Political Subdivision, for the equipment, services and/or
personnel costs as set forth in the forms as supplied and required by the State and the
applicable reimbursement forms reviewed and approved by the State. The funds shall only
be released by the Fiduciary after the applicable reimbursement forms, required by the State
and the Fiduciary, are properly executed by the Parties. The Fiduciary’s Emergency
Management representative/designee shall execute the forms on behalf of the Fiduciary and
the Manager of Oakland County Homeland Security/Emergency Division shall execute the
forms on behalf of the Political Subdivision. The Fiduciary in its sole discretion shall
determine if the reimbursement forms are properly executed.
3.5. The Fiduciary shall create and maintain, an inventory of all equipment purchased with Grant
Program funds in accordance with 2 CFR, Part 200.313 located at http://www.ecfr.gov.
3.6. The Fiduciary shall notify the Political Subdivision at the end of the Fiduciary’s fiscal year of
the dollar amount of Grant Program funds released to the Political Subdivision for that fiscal
year. This amount shall include the dollar amount of equipment purchased with Grant
Program funds by the Political Subdivision.
3.7. The Fiduciary shall file this Agreement pursuant to law and provide executed copies of this
Agreement to the Region 2 Planning Board Secretary and the Political Subdivision.
4.POLITICAL SUBDIVISION RESPONSIBILITIES.
4.1. The Political Subdivision is entitled to reimbursement of allowable expenses for the Grant
Program in an amount not to exceed $36,254 SHSP funding source; and $534,978 in
the UASI funding source. This amount does not include Grant Program funds allocated
to the Region 2 Designated Funding Allocation.
4.2. The Political Subdivision shall prepare all required forms for the use of Grant Program funds
and shall submit such forms to the Region 2 Planning Board for review and approval via the
process designated by the Region 2 Planning Board. Upon approval from the Region 2
Planning Board, the Fiduciary will forward the required forms to the State for review and
approval.
4.3. All funds allocated to the Political Subdivision in Section 4.1 require proof of encumbrance
or requests for reimbursement received by the Fiduciary no later than 5:00 p.m. on November
30, 2024. Grant funds which are not encumbered, or which do not have reimbursement
requests received by the Fiduciary by this date will be reallocated to the Region 2 Designated
Funding Allocation.
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2022 Homeland Security Grant Program Funding Agreement – 04182023
4.4. The Political Subdivision shall use the equipment purchased with Grant Program funds, and
all Grant Program funds in accordance with the 2022 Homeland Security Grant Program
Guidance.
4.5. The Political Subdivision shall keep the Fiduciary informed of the location of the equipment
purchased with Grant Program funds regardless of who purchased the equipment. If the
equipment by its nature is mobile, the Political Subdivision must provide a general location
or “home-base” where the equipment can be found. If the location of the equipment changes,
the Political Subdivision shall provide the new location to the Fiduciary immediately. The
information required by this Section shall be provided to the Fiduciary upon receipt of the
equipment by the Political Subdivision and continue until three (3) years after the close of
this Grant Program.
4.6. The Political Subdivision shall list the dollar amount provided by the Fiduciary pursuant to
Section 3.6 on the Political Subdivision’s Schedule of Expenditures of Federal Awards.
4.7. Except for equipment that is disposable or expendable, the Political Subdivision shall inform
the Fiduciary if it plans to dispose of the equipment and work with the Fiduciary regarding
any issues associated with disposal of the equipment.
4.8. The Political Subdivision shall make the equipment available to the Fiduciary, the State and
Federal Auditors upon request.
4.9. The Political Subdivision shall comply with National Incident Management System (NIMS)
requirements to be eligible to receive federal preparedness funds.
4.10. The Political Subdivision shall comply with applicable financial and administrative
requirements set forth in the current edition of 2 CFR, Part 200, including, but not limited to
the following provisions:
a.Account for receipts and expenditures; maintain adequate financial records and refund
expenditures disallowed by federal or state audit.
b.Retain all financial records, statistical records, supporting documents, and other pertinent
materials for at least three years after the grant is closed by the awarding federal agency
for purposes of federal and/or state examination and audit.
c.Retain all financial records, statistical records, supporting documents, and other pertinent
materials for equipment purchases for three years after their disposition.
d.Non-federal organizations which expend $750,000 or more in federal funds during their
current fiscal year are required to have an audit performed in accordance with the Single
Audit Act of 1984, as amended, and 2 CFR, Part 200.
4.11. The Political Subdivision must carry out their programs and activities in a manner that
respects and ensures the protection of civil rights for protected populations. These
populations include but are not limited to individuals with disabilities and others with access
and functional needs, individuals with limited English proficiency, and other diverse racial
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2022 Homeland Security Grant Program Funding Agreement – 04182023
and ethnic populations, in accordance with Section 504 of the Rehabilitation Act of 1973,
Title VI of the Civil Rights Act of 1964, and Executive Order 13347.
.
4.12. Environmental and Historic Preservation Compliance: The federal government is required to
consider the potential impacts to the human and natural environment of projects proposed for
federal funding. The Environmental and Historic Preservation (EHP) program engages in a
review process to ensure that federally-funded activities comply with various federal laws.
The goal of these compliance requirements is to protect our nation’s water, air, coastal,
wildlife, agricultural and low-income and minority populations. The Political Subdivision
shall not undertake any project having the potential to impact EHP resources without prior
approval. Any activities that have been initiated without the necessary EHP review and
approval will result in a non-compliance finding and will not be eligible for federal funding.
4.13 The Political Subdivision shall comply with the Davis-Bacon Act (40 U.S.C. 3141 et seq) for
grant funded construction projects. The Political Subdivision must ensure that contractors or
subcontractors for construction projects pay workers employed directly at the work-site no less
than the prevailing wages and fringe benefits paid on projects of a similar character.
Additional information, including Department of Labor wage determinations is located at:
http://www.dol.gov/whd/govcontracts/dbra.htm.
4.14 Upon request, the Political Subdivision will supply to the Subgrantor any information
required to meet federally- mandated reporting requirements, including, but not limited to,
requirements related to the Federal Funding Accountability and Transparency Act of 2006
(FFATA) (Public Law 109-282), as amended by Section 6202(a) of the Government
Funding Transparency Act of 2008 (Public Law 110-252) and D HS program specific
reporting requirements.
4.15 The Political Subdivision must acknowledge and agree to comply with applicable
provisions governing U.S. Department of Homeland Security (DHS) access to records,
accounts, documents, information, facilities, and staff. The Political Subdivision also
agrees to require any subrecipients, contractors, successors, transferees, and assignees to
acknowledge and agree to comply with these same provisions. Detailed information on
record access provisions can be found in the D HS Standard Administrative Terms and
Conditions located at https://www.dhs.gov/publication/fy15-dhs-standard-
terms-and-conditions, specifically in the DHS Specific Acknowledgements and
Assurances on page 1.
4.16 The political subdivision shall comply with any minimum expenditures established by the
Region 2 Homeland Security Planning Board intended to ensure compliance with DHS
National Priorities (NP) and the Law Enforcement Terrorism Prevention Allocation (LETPA),
as well as any maximum personnel expenditures established by the board to ensure
compliance with the PRICE Act.
5.REGION 2 PLANNING BOARD RESPONSIBILITIES. The Parties agree and acknowledge
that the Region 2 Planning Board shall have the following responsibilities:
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2022 Homeland Security Grant Program Funding Agreement – 04182023
5.1. Undertake studies and make recommendations on matters of emergency management and
homeland security to Political Subdivisions in the Region;
5.2. Prepare and present to the State Homeland Security Advisory Council findings of activities
and initiatives undertaken in the Region;
5.3. Hold public meetings, subject to the Michigan Open Meetings Act;
5.4. Perform such other acts or functions as it may deem necessary or appropriate to fulfill the
duties and obligations imposed by Federal and State homeland security program
requirements;
5.5. Establish sub-committees to carry out its work;
5.6. Advocate for, monitor, and actively engage in the implementation of the Regional Homeland
Security Strategy; and
5.7. Review and approve all required forms for the expenditure of Grant Program funds that are
submitted.
5.8. Ensure that all grant projects are aligned to the appropriate Threat and Hazard Identification
and Risk Assessment (THIRA). Projects to be funded by SHSP must support closing a
capability gap identified in the State of Michigan THIRA. Projects to be funded by UASI
must support closing a capability gap identified in the Detroit/Southeast Michigan THIRA.
5.9. Ensure the Subgrantee, in its role as regional fiduciary, is fully apprised of all projects
approved by the Region 2 Homeland Security Planning Board.
5.10. Develop and implement a stand-alone Southeast Michigan Urban Area Security Initiative
(SEMI UASI) Multi-Year Training and Exercise Plan or provide evidence of the SEMI
UASI’s adoption and utilization of the state’s Multi-Year Training and Exercise Plan.
5.11. Establish minimum expenditures for each political subdivision to support implementation of
the NP and LETPA, and maximum personnel expenditures to ensure compliance with the
PRICE Act.
6.DURATION OF INTERLOCAL AGREEMENT.
6.1. The Agreement and any amendments hereto shall be effective when executed by both Parties
with resolutions passed by the governing bodies of each Party and shall end three (3) years
from the date the Grant Program is closed. The approval and terms of this Agreement and
any amendments hereto shall be entered in the official minutes of the governing bodies of
each Party.
7.LIABILITY/ASSURANCES.
7.1. Each Party shall be responsible for any Claim made against that Party by a third party, and
for the acts of its employees or agents arising under or related to this Agreement.
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2022 Homeland Security Grant Program Funding Agreement – 04182023
7.2. In any Claim that may arise under or relate to this Agreement, each Party shall seek its own
legal representation and bear the costs associated with such representation, including attorney
fees.
7.3. Neither Party shall have any right under any legal principle to be indemnified by the other
Party or any of its employees or agents in connection with any Claim.
7.4. Notwithstanding any other provision of this Agreement, the Political Subdivision shall be
solely responsible for all costs, fines, and fees associated with the use and misuse of Grant
Program funds that it receives or the use or misuse of the equipment, including but not
limited to, costs for replacing the equipment or costs, fines, or fees associated with an
ineligible use determination by auditors.
7.5. The Parties have taken all actions and secured all approvals necessary to authorize and
complete this Agreement. The persons signing this Agreement on behalf of each Party have
legal authority to sign this Agreement and bind the Parties to the terms and conditions
contained herein.
7.6. Each Party shall comply with all federal, state, and local ordinances, regulations,
administrative rules, laws, and requirements applicable to its activities performed under this
Agreement, including but not limited to the Grant Program Agreement, attached as Exhibit
B, and the 2022 Homeland Security Grant Program Guidance.
8.TERMINATION OR CANCELLATION OF AGREEMENT. Either Party may terminate and/or
cancel this Agreement upon thirty (30) Days notice to the other Party. The effective date of
termination and/or cancellation shall be clearly stated in the notice. If this Agreement is terminated
and/or cancelled, the Transfer of Ownership Agreements executed prior to the date of termination
and/or cancellation, shall remain valid and govern the Parties’ duties and obligations regarding
equipment transferred to the Political Subdivision and the Parties shall execute Transfer of
Ownership Agreements for all equipment ordered by the Fiduciary prior to the date of termination
and/or cancellation.
9.NO THIRD PARTY BENEFICIARIES. Except as provided for the benefit of the Parties, this
Agreement does not and is not intended to create any obligation, duty, promise, contractual right or
benefit, right to indemnification, right to subrogation, and/or any other right, in favor of any other
person or entity.
10.DISCRIMINATION. The Parties shall not discriminate against their employees, agents, applicants
for employment, or another persons or entities with respect to hire, tenure, terms, conditions, and
privileges of employment, or any matter directly or indirectly related to employment in violation of
any federal, state or local law.
11.PERMITS AND LICENSES. Each Party shall be responsible for obtaining and maintaining,
throughout the term of this Agreement, all licenses, permits, certificates, and governmental
authorizations necessary to carry out its obligations and duties pursuant to this Agreement.
12.RESERVATION OF RIGHTS. This Agreement does not, and is not intended to waive, impair,
divest, delegate, or contravene any constitutional, statutory, and/or other legal right, privilege,
power, obligation, duty, or immunity of the Parties.
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2022 Homeland Security Grant Program Funding Agreement – 04182023
13.DELEGATION/SUBCONTRACT/ASSIGNMENT. Neither Party shall delegate, subcontract,
and/or assign any obligations or rights under this Agreement without the prior written consent of the
other Party.
14.NO IMPLIED WAIVER. Absent a written waiver, no act, failure, or delay by a Party to pursue or
enforce any rights or remedies under this Agreement shall constitute a waiver of those rights with
regard to any existing or subsequent breach of this Agreement. No waiver of any term, condition, or
provision of this Agreement, whether by conduct or otherwise, in one or more instances, shall be
deemed or construed as a continuing waiver of any term, condition, or provision of this Agreement.
No waiver by either Party shall subsequently affect its right to require strict performance of this
Agreement.
15.SEVERABILITY. If a court of competent jurisdiction finds a term, or condition, of this Agreement
to be illegal or invalid, then the term, or condition, shall be deemed severed from this Agreement.
All other terms, conditions, and provisions of this Agreement shall remain in full force.
16.CAPTIONS. The section and subsection numbers, captions, and any index to such sections and
subsections contained in this Agreement are intended for the convenience of the reader and are not
intended to have any substantive meaning. The numbers, captions, and indexes shall not be
interpreted or be considered as part of this Agreement. Any use of the singular or plural number,
any reference to the male, female, or neuter genders, and any possessive or nonpossessive use in this
Agreement shall be deemed the appropriate plurality, gender or possession as the context requires.
17.NOTICES. Notices given under this Agreement shall be in writing and shall be personally
delivered, sent by express delivery service, certified mail, or first class U.S. mail postage prepaid,
and addressed to the person listed below. Notice will be deemed given on the date when one of the
following first occur: (1) the date of actual receipt; (2) the next business day when notice is sent
express delivery service or personal delivery; or (3) three days after mailing first class or certified
U.S. mail.
17.1. If Notice is sent to the Fiduciary, it shall be addressed and sent to: Macomb County Office of
Emergency Management and Communications, 117 S. Groesbeck, Mt. Clemens, MI 48043.
17.2. If Notice is sent to the Political Subdivision, it shall be addressed to: Oakland County Board
of Commissioners, 1200 North Telegraph Rd., Pontiac, MI 48341 and Oakland County Homeland
Security Manager, 1200 N. Telegraph Rd., Building 47 West, Pontiac, MI 48341.
17.3. Either Party may change the address and/or individual to which Notice is sent by notifying the other Party in writing of the change.
18.GOVERNING LAW. This Agreement shall be governed, interpreted, and enforced by the laws of
the State of Michigan.
19.AGREEMENT MODIFICATIONS OR AMENDMENTS. Any modifications, amendments,
recessions, waivers, or releases to this Agreement must be in writing and executed by both Parties.
20.ENTIRE AGREEMENT. This Agreement represents the entire agreement and understanding
between the Parties. This Agreement supersedes all other oral or written agreements between the
Parties. The language of this Agreement shall be construed as a whole according to its fair meaning,
and not construed strictly for or against any Party.
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2022 Homeland Security Grant Program Funding Agreement – 04182023
IN WITNESS WHEREOF,
EXECUTED: ____________________________________ DATE: ______________
Andrew S. McKinnon,
Deputy County Executive
Macomb County Executive Office
WITNESSED: _____________________________________ DATE: _______________
Political Subdivision: Oakland County
EXECUTED: ___________________________________ DATE: ______________
WITNESSED: __________________________________ DATE: ______________
EMERGENCY MANAGEMENT & COMMUNICATIONS
117 South Groesbeck Highway • Mount Clemens, Michigan 48043
Phone: 586.469.5270 • Fax: 586.469.6439
oemc.macombgov.org
Kim Richmond
Preparedness Grants Unit Manager
Emergency Management and Homeland Security Division
Michigan State Police
PO Box 30634
Lansing, MI 48909
Kim,
At its meeting on August 17, 2022, the Region 2 Homeland Security Planning Board
voted unanimously to appoint Macomb County as the regional fiduciary for the FY
2022 Homeland Security Grant Program.
I am providing you with this letter at the behest of the board as the official minutes
from that meeting currently do not clearly reflect that. This issue will be addressed by
the board and the minutes will be amended at a future meeting.
Please contact me if you have any questions.
Sincerely,
Brandon Lewis
Director
Macomb County Emergency Management and Communications
Chairperson, Region 2 Homeland Security Planning Board
Brandon Lewis, PEM
Director
Kristina Krieger, PEM
Emergency Program
Manager
Sean McCarthy
Technical Services
Manager
Michael Curtis
Homeland Security
Grant Manager
Mark A. Hackel
County Executive
EMERGENCY MANAGEMENT & COMMUNICATIONS
117 South Groesbeck Highway • Mount Clemens, Michigan 48043
Phone: 586.469.5270 • Fax: 586.469.6439
oemc.macombgov.org
To Oakland County
In addition to the award amounts detailed in your 2022 HSGP Interlocal Agreement
the Urban Area Security Initiative (UASI) Board has allocated project funds from the
Region 2 HSGP Designated Funding Allocation for the UASI 2022 award
performance period. The 2022 UASI performance period is September 1, 2022, to
May 31, 2025.
Oakland has been allocated an additional award amount:
1. DSEMIIC Analyst personnel (2): Full salary and travel expenses requested
up to $220,000 combined.
This project is to be reimbursed from the Designated Funding Allocation through
Macomb County as the fiduciary.
Sincerely,
Michael Curtis
Homeland Security Grant Manager
Brandon Lewis, PEM
Director
Kristina Krieger, PEM
Emergency Program
Manager
Sean McCarthy
Technical Services
Manager
Michael Curtis
Homeland Security
Grant Manager
Mark A. Hackel
County Executive
1
Michigan Fact Sheet: Fiscal Year 2022 Homeland Security Grant Program Overview
Introduction
The Fiscal Year (FY) 2022 Homeland Security Grant Program (HSGP) is one of three grant programs that
constitute the Department of Homeland Security (DHS) Federal Emergency Management Agency’s (FEMA)
focus on enhancing the ability of state, local, tribal, and territorial governments, as well as nonprofits, to
prevent, protect against, respond to, and recover from terrorist attacks. The grant programs are part of a
comprehensive set of measures authorized by Congress and implemented by DHS to help strengthen the
Nation’s communities against potential terrorist attacks. The HSGP supports DHS’s goal to Strengthen
National Preparedness and Resilience.
The three HSGP programs include: State Homeland Security Program (SHSP), Urban Area Security
Initiative (UASI), and Operation Stonegarden (OPSG). For additional information on allowable activities
under these grant programs, please refer to https://www.fema.gov/grants/preparedness. The scope of this
document will focus on the SHSP and UASI.
FY 2022 Programmatic Highlights and Requirements
Authorizing Authority for Program
Section 2002 of the Homeland Security Act of 2002, as amended (Public Law 107-296, as amended), (6
U.S.C. § 603).
Appropriation Authority for Program
The Department of Homeland Security Appropriations Act, 2022 (Public Law 117-103).
Consistent with thresholds established in the Homeland Security Act of 2002, as amended, all 50 states, the
District of Columbia, and the Commonwealth of Puerto Rico received 0.35 percent of the total funds allocated
for grants under Section 2003 and Section 2004 of the Homeland Security Act of 2002, as amended. The
remaining SHSP funds were distributed based upon the Department of Homeland Security’s (DHS) relative risk
methodology. Eligible candidates for the FY 2022 UASI program were determined through an analysis of the
relative risk of terrorism faced by the 100 most populous Metropolitan Statistical Areas.
National Priority Funding Requirements
DHS/FEMA continuously evaluates the national risk profile and sets priorities that help ensure appropriate
allocation of scarce security dollars. In assessing the national risk profile for 2022, six priority areas attracted
the most concern. Due to the unique threats that the nation faces in 2022, DHS/FEMA determined a total of
30 percent of SHSP and UASI funds must be allocated to these six priority areas. Subrecipients are required
to dedicate a percentage of their funds to these priority areas at the rates listed below which total 12 percent
of SHSP and UASI awards. Subrecipients have flexibility to allocate the remaining 18 percent across the
priorities. Minimum amounts are specified in the subrecipient grant agreement.
The six priority areas include:
▪ Enhancing the protection of soft targets/crowded places – 3 percent
▪ Enhancing information and intelligence sharing and cooperation with federal agencies – 3 percent
▪ Combating domestic violent extremism – 3 percent
▪ Enhancing community preparedness and resilience – 3 percent
▪ Enhancing cybersecurity – no minimum percent
▪ Enhancing election security – no minimum percent
All FY 2022 national priority area project narratives are due to the Michigan State Police Emergency
Management and Homeland Security Division by November 15, 2022.
Whole Community Preparedness
Subrecipients must engage with the whole community to advance community and individual preparedness and
to work as a nation to build and sustain resilience. Subrecipients must also integrate program design and
2
delivery practices that ensure representation and services for under-represented, diverse populations that may
be more impacted by disasters.
Collaboration with Tribes
Subrecipients are strongly encouraged to work with tribal nations in overall initiatives such as whole
community preparedness and emergency management planning.
Collaboration with Nonprofit Organizations
Subrecipients are encouraged to work with the nonprofit community to address terrorism and all hazard
prevention concerns, seek input on the needs of the nonprofit sector, and support the goals of their
investments.
Law Enforcement Terrorism Prevention Activities (LETPA)
Section 2006 of the Homeland Security Act of 2002, as amended, requires at least 25 percent of HSGP
funds to be used for LETPA. For FY 2022, DHS/FEMA is requiring at least 30 percent of HSGP grant
funding be dedicated towards LETPA.
Individual subrecipient LETPA requirements are listed below and are included in the grant agreements.
Activities outlined in the National Prevention Framework are eligible for use of LETPA focused funds. In
addition, where capabilities are shared with the protection mission area, the National Protection Framework
activities are also eligible. For additional information, visit: National Planning Frameworks.
Personnel Activities (SHSP and UASI)
Personnel hiring, overtime, and backfill expenses are permitted under this grant to perform allowable HSGP
activities. A personnel cap of up to 50 percent of HSGP program funds may be used for personnel and
personnel-related activities. In general, the use of SHSP and UASI funding to pay for staff and/or contractor
regular time or overtime/backfill is considered a personnel cost.
Award Period of Performance
The FY 2022 HSGP period of performance is 36 months. For subrecipient performance period dates, refer to
subrecipient grant agreements.
Management and Administration (M&A) Limits
A maximum of up to 5 percent of subrecipient HSGP funds awarded may be retained and used solely for the
purposes of management and administration associated with the HSGP award.
2022 Nationwide Cybersecurity Review (NCSR)
Subrecipients of FY 2022 HSGP funds are required to complete the 2022 NCSR, enabling agencies to
benchmark and measure progress of improving their cybersecurity posture. The Chief Information Officer
(CIO), Chief Information Security Officer (CISO) or equivalent should complete the NCSR. If there is no CIO
or CISO, the most senior cybersecurity professional should complete the assessment. The 2022 NCSR is
estimated to be open from October 2022 – February 2023.
Environmental Planning and Historic Preservation (EHP) Compliance
FEMA is required to consider the effects on the environment and/or historic properties of any federally
funded activities and programs, including grant funded projects. The EHP Program engages in a review
process to ensure that federally funded activities comply with federal EHP regulations, laws, and Executive
Orders, as applicable. Subrecipients shall not undertake any project having the potential to impact EHP
resources without prior approval. Subrecipients shall provide all relevant information through the established
Michigan State Police, Emergency Management and Homeland Security Division (MSP/EMHSD) process to
ensure compliance with applicable federal EHP requirements.
Ensuring the Protection of Civil Rights
As the Nation works towards achieving the National Preparedness Goal, it is important to continue to protect
the civil rights of individuals. Subrecipients must carry out their programs and activities, including those
related to the building, sustainment, and delivery of core capabilities, in a manner that respects and ensures
3
the protection of civil rights for protected populations, in accordance with Section 504 of the Rehabilitation
Act of 1973, Title VI of the Civil Rights Act of 1964, and related statues. The DHS Standard Terms and
Conditions include civil rights provisions that apply to subrecipients. These terms and conditions can be
found on the DHS website or accessed here: DHS Standard Terms and Conditions.
Collaboration with other Federal Preparedness Programs
DHS/FEMA strongly encourages subrecipients of HSGP funds to understand other federal preparedness
programs in their jurisdictions and to work with them in a collaborative manner to leverage all available
resources and avoid duplicative activities. For example, the U.S. Department of Health and Human Services
has two robust preparedness programs that focus on preparedness capabilities. C oordination is not limited to
just these programs or just to grant funding. It also includes leveraging assessments such as TSA’s Baseline
Assessment and Security Enhancement (BASE); reporting from the Intelligence Community, risk information
such as U.S. Coast Guard’s Maritime Security Risk Analysis Model (MSRAM), and USBP Sector Analysis.
FY 2022 HSGP Allocations and Funding Requirements
Table 1: Available Funds
Table 1 illustrates Michigan’s FY 2022 HSGP awards in relation to the total amount available nationwide
and identifies the total available for regional/local programs in Michigan.
FY 2022 HSGP Funding SHSP UASI
Nationwide $415,000,000 $615,000,000
Statewide $5,085,387 $5,250,000
Regional/local Share $4,068,310 $4,200,000
Table 2: LETPA Funding Requirements
A minimum of 30 percent of SHSP and UASI funding must be
dedicated towards law enforcement terrorism prevention activities.
As shown in Table 2, regions must collectively dedicate $2,480,493
of SHSP and UASI funds towards law enforcement terrorism
prevention activities to meet the minimum funding requirement.
Table 3: Regional FY 2022 HSGP Allocations
Table 3 outlines the individual
allocations awarded to each
region for the FY 2022
Homeland Security Grant
Program period of performance.
The table also provides each
region with the minimum dollar
amount from the allocation that
is required to be dedicated
toward meeting the LETPA
funding requirement outlined in
the FY 2022 HSGP Notice of
Funding Opportunity.
1 Note: The LETPA requirement for Region 2 can be met through any combination of SHSP and UASI funds, so long as
the cumulative total between the two programs is $1,345,386.
Regional Amount Obligated to
Law Enforcement Terrorism
Prevention Activities
SHSP & UASI $2,480,493
Region SHSP Allocation LETPA Minimum
1 $775,833 $232,750
2 $284,619 $85,386
3 $772,477 $231,744
5 $632,517 $189,756
6 $991,312 $297,394
7 $305,944 $91,784
8 $305,608 $91,683
Region UASI Allocation LETPA Minimum1
2 $4,200,000 $1,260,000
Preparedness Grants Manual | May 2022 1
FEMA Manual (FM) 207-22-0001
Fiscal Year 2022 Preparedness
Grants Manual
FEMA Grant Programs Directorate
Version 3, MAY 2022
Preparedness Grants Manual | May 2022 2
Table of Contents
Table of Contents 2
About the Federal Emergency Management Agency (FEMA) 7
Overview of FEMA 7
Overview of Preparedness Grant Programs 7
Homeland Security Grant Program (HSGP) 7
Tribal Homeland Security Grant Program (THSGP) 7
Nonprofit Security Grant Program (NSGP) 8
Transit Security Grant Program (TSGP) 8
Intercity Bus Security Grant Program (IBSGP) 8
Intercity Passenger Rail (IPR) Program – Amtrak 8
Port Security Grant Program (PSGP) 8
Emergency Management Performance Grant (EMPG) Program 8
Foreword 9
The National Preparedness Goal 9
Pre-Award Application and Submission 10
Pre-Submission Information 10
Agreeing to Terms and Conditions of the Award 10
Address to Request Application Package 11
Steps Required to Obtain a Unique Entity Identifier, Register in the System for Award Management
(SAM), and Submit an Application 11
Electronic Delivery 12
How to Register to Apply through Grants.gov 12
How to Submit an Initial Application to DHS/FEMA via Grants.gov 14
Submitting the Final Application in ND Grants 15
Timely Receipt Requirements and Proof of Timely Submission 16
Standard Required Application Forms and Information 16
Intergovernmental Review 17
Funding Restrictions and Allowable Costs 17
Award Determination and Obligation 21
Allocations 21
Risk Methodology 21
Application Evaluation Criteria 21
Supplemental Financial Integrity Review 22
Review and Selection Process 22
Federal Award Administration Information 22
Notice of Award 22
Pass-Through Requirements 23
Preparedness Grants Manual | May 2022 3
Administrative and National Policy Requirements 23
Post-Award Management and Implementation 28
Reporting 28
Federal Financial Reporting Requirements 28
Federal Financial Report (FFR) 28
Financial Reporting Periods and Due Dates 28
Program Performance Reporting Requirements 28
Performance Progress Report (PPR) 28
Program Performance Reporting Periods and Due Dates 29
Additional Programmatic Reporting Requirements and Information 29
Biannual Strategy Implementation Report (BSIR) 29
Closeout Reporting Requirements 29
Administrative Closeout 30
Disclosing Information per 2 C.F.R. § 180.335 31
Reporting of Matters Related to Recipient Integrity and Performance 31
Single Audit Report 31
Additional Information 32
Monitoring and Oversight 32
Overview 32
Financial Monitoring Overview and Approach 33
Programmatic Monitoring Overview and Approach 35
Case Studies and Use of Grant-Funded Resources During Real-World Incident Operations 36
Termination Provisions 36
Period of Performance (POP) Extensions 36
Disability Integration 37
Conflicts of Interest in the Administration of Federal Awards or Subawards 38
Procurement Integrity 39
Important Changes to Procurement Standards in 2 C.F.R Part 200 39
Competition and Conflicts of Interest 40
Supply Schedules and Purchasing Programs 41
Records Retention 43
Actions to Address Noncompliance 44
Audits 45
Payment Information 46
National Campaigns and Programs 47
FEMA Strategic Plan 47
Whole Community Preparedness 47
Active Shooter Preparedness 48
Soft Targets and Crowded Places 48
Community Lifelines 49
Strategic Framework for Countering Terrorism and Targeted Violence 50
Countering Violent Extremism (CVE) Training 50
Preparedness Grants Manual | May 2022 4
Program Appendix A: Homeland Security Grant Program (HSGP) A-1
Alignment of HSGP to the National Preparedness System A-1
HSGP Funding Guidelines A-2
Reporting on the Implementation of the National Preparedness System A-21
Identifying and Assessing Risk and Estimating Capability Requirements A-21
Building and Sustaining Capabilities A-22
National Incident Management System (NIMS) Implementation A-22
Planning to Deliver Capabilities A-22
Validating Capabilities A-23
Fusion Centers A-24
Fusion Center Performance Measures A-26
Continuity Capability A-27
Governance A-28
Supplemental SHSP and UASI Guidance A-32
Supplemental OPSG Program Guidance A-35
OPSG Operational Guidance A-37
HSGP Supplemental Material A-44
Supplemental Emergency Communications Guidance A-46
Program Appendix B: Tribal Homeland Security Grant Program (THSGP) B-1
Alignment of THSGP to the National Preparedness System B-1
THSGP Funding Guidelines B-4
THSGP Priorities B-4
Allowable Costs B-4
THSGP Investment Modifications – Changes in Scope or Objective B-13
Program Appendix C: Nonprofit Security Grant Program (NSGP) C-1
NSGP Funding Guidelines C-1
NSGP Priorities C-1
Allowable Costs C-1
NSGP Investment Modifications – Changes in Scope or Objective C-7
Pass-Through Requirements C-8
SAM/UEI Requirements for Recipients and Subrecipients C-9
Program Appendix D: Transit Security Grant Program (TSGP) D-1
TSGP Funding Guidelines D-1
Pre-Award Costs D-1
TSGP Priorities D-1
Security Plan Requirements D-1
Allowable Direct Costs D-2
Allowable Indirect Costs D-12
Unallowable Costs D-12
Maintenance and Sustainment Costs D-13
Encouraged Use of Certain Products Produced in the United States D-13
Program Appendix E: Intercity Bus Security Grant Program (IBSGP) E-1
Preparedness Grants Manual | May 2022 5
IBSGP Priorities E-1
Pre-Award Costs E-1
Allowable Direct Costs E-1
Indirect Costs (Facilities and Administration [F&A]) E-7
Unallowable Costs E-8
Other Allowable Costs E-8
Encouraged Use of Certain Products Produced in the United States E-9
Program Appendix F: Intercity Passenger Rail (IPR) Program F-1
IPR Funding Guidelines F-1
IPR Priorities F-1
Security Plan Requirements F-1
Allowable Costs F-2
Operational Activities F-3
Funding Availability for OPacks F-4
Specific Guidance on EDCT F-5
Program Appendix G: Port Security Grant Program (PSGP) G-1
PSGP Funding Guidelines G-1
PSGP Priorities G-1
Limitations on Funding G-1
Allowable Direct Costs G-2
Port-Wide Risk Management Plans G-17
Sample Memorandum of Understanding/Agreement (MOU/MOA) G-17
PSGP Investment Modifications G-18
Program Appendix H: Emergency Management Performance Grant Program (EMPG) H-1
EMPG Program Priorities H-1
Alignment of the EMPG Program to the National Preparedness System H-1
Implementation of the National Preparedness System H-2
Identifying and Assessing Risk and Estimating Capability Requirements H-2
Building and Sustaining Core Capabilities H-2
National Incident Management System (NIMS) Implementation H-2
National Qualifications System (NQS) Implementation H-3
Logistics Planning H-4
Distribution Management Plans H-4
Additional Logistics Planning Resources H-5
Funding for Critical Emergency Supplies H-6
Evacuation Planning H-6
Disaster Housing Planning H-6
State Disaster Recovery Coordinator H-8
Disaster Financial Management Policies and Procedures H-8
Training and Exercises H-10
Reviewing and Updating Planning Products H-14
Additional Considerations H-14
Program Performance Reporting Requirements H-14
Preparedness Grants Manual | May 2022 6
Performance Progress Reports (PPR) H-14
Standardized Programmatic Reporting for the EMPG Program H-15
EMPG Program Funding Guidelines H-16
Allowable Costs H-16
Management and Administration (M&A) H-16
Indirect Costs H-16
Unrecovered Indirect Costs H-16
Whole Community Preparedness H-17
Planning H-18
Continuity Planning H-19
Organization H-20
Equipment H-20
Training H-22
Exercises H-23
Construction and Renovation H-24
Acquisition of Real Property H-25
Leasing of Real Property H-26
Maintenance and Sustainment H-26
Unallowable Costs H-27
EMPG Program Work Plan H-28
EMPG Program Work Plan Instructions H-29
Definitions and Guidance H-29
Quick Links H-29
Grant Investment Strategy H-29
Grant Activities Outline H-30
Detailed Budget – Excluding M&A H-32
Budget Narrative – Excluding M&A H-32
Detailed Budget – M&A Only H-33
Budget Narrative – M&A Only H-33
Information for the Detailed Budget and Budget Narrative H-33
EMPG Program Summary H-35
Implementation Schedule H-36
Training Data Table H-36
Exercise Data Table H-37
Preparedness Grants Manual | May 2022 7
About the Federal Emergency Management
Agency (FEMA)
Overview of FEMA
FEMA has helped people before, during, and after disasters for more than 40 years. FEMA remains
committed to building and developing a culture of preparedness across the country and unifying all levels
of community and government in an integrated approach to emergency management. FEMA is part of a
larger team of federal agencies, state, local, tribal, and territorial (SLTT) governments, as well as non-
governmental partners, that share responsibility for emergency management and national preparedness.
Those closest to impacted areas are the true first responders during any emergency or disaster—
individuals, families, neighbors, and local communities. FEMA’s role is to coordinate federal resources to
supplement SLTT capabilities. FEMA does this by coordinating through the levels of government,
meaning that states and their local units of government, tribes, and territories are our primary partners.
Overview of Preparedness Grant Programs
FEMA has the statutory authority to deliver numerous disaster and non-disaster financial assistance
programs in support of its mission, and that of the Department of Homeland Security, largely through
grants and cooperative agreements. These programs account for a significant amount of the federal funds
for which FEMA is accountable. FEMA officials are responsible and accountable for the proper
administration of these funds pursuant to federal laws and regulations, Office of Management and Budget
circulars, and federal appropriations law principles. FEMA has developed this Manual to provide
additional direction on grant policy and implementation for the following grant programs:
Homeland Security Grant Program (HSGP)
The HSGP includes a suite of risk-based grants to assist SLTT efforts in preventing, preparing for,
protecting against, and responding to acts of terrorism. The grants under HSGP include:
• State Homeland Security Program (SHSP)
The SHSP assists state, local, tribal, and territorial efforts to build, sustain, and deliver the
capabilities necessary to prevent, prepare for, protect against, and respond to acts of terrorism.
• Urban Area Security Initiative (UASI)
The UASI Program assists high-risk urban areas’ efforts to build, sustain, and deliver the
capabilities necessary to prevent, prepare for, protect against, and respond to acts of terrorism.
• Operation Stonegarden (OPSG)
OPSG supports enhanced cooperation and coordination among Customs and Border Protection
(CBP), United States Border Patrol (USBP), and federal, state, local, tribal, and territorial law
enforcement agencies to improve overall border security. OPSG provides funding to support joint
efforts to secure the United States’ borders along routes of ingress/egress to and from
international borders, to include travel corridors in states bordering Mexico and Canada, as well
as states and territories with international water borders. SLTT law enforcement agencies utilize
their own law enforcement authorities to support the border security mission and do not receive
any additional authority as a result of participation in OPSG.
Tribal Homeland Security Grant Program (THSGP)
The THSGP provides funding directly to eligible tribes to strengthen their capacity to prevent, prepare
for, protect against, and respond to potential terrorist attacks.
Preparedness Grants Manual | May 2022 8
Nonprofit Security Grant Program (NSGP)
The NSGP provides funding for physical security enhancements and other security-related activities to
nonprofit organizations that are at high risk of a terrorist attack. The NSGP also seeks to integrate the
preparedness activities of nonprofit organizations with broader state and local preparedness efforts.
Transit Security Grant Program (TSGP)
The TSGP provides funds to eligible public transportation systems (which include intra-city bus, ferries,
and all forms of passenger rail) to protect critical transportation infrastructure and the travelling public
from terrorism, and to increase transportation infrastructure resilience.
Intercity Bus Security Grant Program (IBSGP)
The IBSGP provides funds to eligible private operators of intercity over-the-road bus transportation
systems to protect critical transportation infrastructure and travelling public from acts of terrorism, and to
increase transportation infrastructure resilience.
Intercity Passenger Rail (IPR) Program – Amtrak
The IPR provides funds to the National Railroad Passenger Corporation (Amtrak) to protect critical
transportation infrastructure and the travelling public from terrorism, and to increase transportation
infrastructure resilience.
Port Security Grant Program (PSGP)
The PSGP provides funding to port authorities, facility operators, and state and local agencies for
activities associated with implementing Area Maritime Security Plans, facility security plans, and other
port-wide risk management efforts.
Emergency Management Performance Grant (EMPG) Program
The EMPG Program provides funds to assist SLTT emergency management agencies in obtaining the
resources required for implementation of the National Preparedness System and the National
Preparedness Goal of a secure and resilient nation.
Preparedness Grants Manual | May 2022 9
Foreword
FEMA has developed this Preparedness Grants Manual to guide applicants and grant recipients on how
to manage their grants and other resources. Recipients seeking guidance on policies and procedures for
managing preparedness grants should reference this Manual for further information on both program-
specific information as well as overall guidance on rules and regulations that guide the proper
management of FEMA grants.
The National Preparedness Goal
The National Preparedness Goal (the Goal) is “[a] secure and resilient Nation with the capabilities
required across the whole community to prevent, protect against, mitigate, respond to, and recover from
the threats and hazards that pose the greatest risk.” See Department of Homeland Security, National
Preparedness Goal, Second Edition, (Sept. 2015). The Goal essentially defines what it means for all
communities to be prepared collectively for the threats and hazards that pose the greatest risk to the
nation. The Goal identifies 32 distinct activities, called core capabilities, needed to address the risks. The
Goal organizes these core capabilities into five categories, called mission areas. Some core capabilities
apply to more than one mission area. For example, the first three core capabilities—Planning, Public
Information and Warning, and Operational Coordination—are cross-cutting capabilities, meaning they
apply to each of the five mission areas. The National Preparedness Goal describes the five mission areas
as follows:
• Prevention: Prevent, avoid, or stop an imminent, threatened, or actual act of terrorism.
• Protection: Protect our citizens, residents, visitors, and assets against the greatest threats and
hazards in a manner that allows our interests, aspirations, and way of life to thrive.
• Mitigation: Reduce the loss of life and property by lessening the impact of future disasters.
• Response: Respond quickly to save lives, protect property and the environment, and meet basic
human needs in the aftermath of an incident.
• Recovery: Recover through a focus on the timely restoration, strengthening, and revitalization of
infrastructure, housing, and a sustainable economy, as well as the health, social, cultural, historic,
and environmental fabric of communities affected by an incident.
The mission areas and core capabilities organize the activities and tasks performed before, during, and
after disasters into a framework for achieving the goal of a secure and resilient Nation. Resilience is the
desired outcome, defined in the Goal as the “ability to adapt to changing conditions and withstand and
rapidly recover from disruption due to emergencies.” Id. at A-2. For more information about the Goal, go
to https://www.fema.gov/national-preparedness-goal.
Recipients will use the National Preparedness System to build, sustain, and deliver these core capabilities.
The components of the National Preparedness System are Identifying and Assessing Risk, Estimating
Capability Requirements, Building and Sustaining Capabilities, Planning to Deliver Capabilities,
Validating Capabilities, and Reviewing and Updating. Additional information on the National
Preparedness System is available at http://www.fema.gov/national-preparedness-system. Additional
details regarding the National Preparedness System and how it is supported by these grant programs can
be found in the program-specific appendices.
Preparedness Grants Manual | May 2022 10
Pre-Award Application and Submission
Pre-Submission Information
These instructions apply to the following programs:
• Homeland Security Grant Program;1
• Tribal Homeland Security Grant Program;
• Nonprofit Security Grant Program;
• Transit Security Grant Program;
• Intercity Bus Security Grant Program;
• Intercity Passenger Rail Program;
• Port Security Grant Program; and
• Emergency Management Performance Grant Program.
All applications must be received by the established deadline established in each program’s Notice of
Funding Opportunity (NOFO). The Non-Disaster (ND) Grants System has a date stamp that indicates
when an application is submitted. Applicants will receive an electronic message confirming receipt of
their submission. For additional information on how an applicant will be notified of application receipt,
see the section titled “Timely Receipt Requirements and Proof of Timely Submission.”
FEMA will not review applications that are received after the deadline, nor will it consider these
late applications for funding. FEMA may, however, extend the application deadline on request for an
applicant who can demonstrate that good cause exists to justify extending the deadline. Good cause for an
extension may include technical problems outside of the applicant’s control that prevent submission of the
application by the deadline, other exigent or emergency circumstances, or statutory requirements for
FEMA to make an award.
Applicants experiencing technical problems outside of their control must notify the respective
FEMA Preparedness Officer or Program Manager as soon as possible and before the application
deadline. Failure to timely notify FEMA of the issue that prevented the timely filing of the application
may preclude consideration of the award. “Timely notification” of FEMA means the following: prior to
the application deadline and within 48 hours after the applicant became aware of the issue.
For additional assistance using the ND Grants System, please contact the ND Grants Service Desk at
(800) 865-4076 or NDGrants@fema.dhs.gov. The ND Grants Service Desk is available Monday through
Friday, 9 a.m. – 6 p.m. ET. For programmatic or grants management questions, please contact your
Preparedness Officer or Program Manager. If applicants do not know their FEMA Preparedness Officer
or if there are programmatic questions or concerns, please contact the Centralized Scheduling and
Information Desk (CSID) by phone at (800) 368-6498 or by e-mail at askcsid@fema.dhs.gov, Monday
through Friday, 9 a.m. – 5 p.m. ET.
Agreeing to Terms and Conditions of the Award
By submitting an application, the applicant agrees to comply with the requirements of the applicable
NOFO, this Manual, and the applicable appendix to this Manual, as well as the terms and conditions of its
award should it receive an award.
1 Under this program, these instructions apply to SHSP, UASI, and OPSG.
Preparedness Grants Manual | May 2022 11
Address to Request Application Package
Initial applications are processed through the Grants.gov portal. Final applications are completed and
submitted through FEMA’s ND Grants System. Application forms and instructions are available on
Grants.gov; hard copies of the NOFO and associated application materials can be downloaded at
Grants.gov. To access these materials, go to http://www.grants.gov, select “Applicants” then “Apply for
Grants.” In order to obtain the application package, select “Download a Grant Application Package.”
Enter the Assistance Listing (formerly CFDA) and/or the funding opportunity number located on the
cover of the program’s NOFO, select “Download Package,” and then follow the prompts to download the
application package. In addition, the following Telephone Device for the Deaf (TDD) and/or Federal
Information Relay Service (FIRS) number available for this Notice and all relevant NOFOs is (800) 462-
7585.
Steps Required to Obtain a Unique Entity Identifier, Register in the System for Award
Management (SAM), and Submit an Application
Applying for an award under the programs covered by this Manual is a multi-step process and requires
time to complete. Applicants are encouraged to register early, as the registration process can take four
weeks or more to complete. Therefore, registration should be done in sufficient time to ensure it does not
impact the applicant’s ability to meet required submission deadlines. Failure of an applicant to comply
with any of the required steps in submitting an application before the deadline may disqualify that
application from funding consideration.
To apply for an award, all applicants must:
1. Apply for, update, or verify their Unique Entity Identifier (UEI) number from SAM.gov, and
Employer Identification Number (EIN) from the Internal Revenue Service;
2. In the application, provide a UEI number;
3. Have an account with login.gov;
4. Register for, update, or verify their SAM account and ensure the account is active before
submitting the application;
5. Create a Grants.gov account;
6. Add a profile to a Grants.gov account;
7. Establish an Authorized Organizational Representative (AOR) in Grants.gov;
8. Register in ND Grants;
9. Submit an initial application in Grants.gov;
10. Submit the final application in ND Grants, including electronically signing applicable
forms; and
11. Continue to maintain an active SAM registration with current information at all times during
which it has an active federal award or an application or plan under consideration by a federal
awarding agency. As part of this, applicants must also provide information on an applicant’s
immediate and highest-level owner and subsidiaries, as well as on all predecessors that have been
awarded federal contracts or federal financial assistance within the past three years, if applicable.
Specific instructions on how to apply for, update, or verify a UEI number or SAM registration or establish
an AOR are included in the steps below for applying through Grants.gov. Applicants are advised that
FEMA may not make a federal award until the applicant has complied with all applicable UEI and SAM
requirements. Therefore, an applicant’s SAM registration must be active not only at the time of
application, but also during the application review period and when FEMA is ready to make a federal
award. Further, as noted above, an applicant’s or recipient’s SAM registration must remain active for the
duration of an active federal award. If an applicant’s SAM registration is expired at the time of
application, expires during application review, or expires any other time before award, FEMA may
Preparedness Grants Manual | May 2022 12
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.
Per 2 C.F.R. § 25.110(c)(2)(iii), if an applicant is experiencing exigent circumstances that prevent it from
receiving a UEI number and completing SAM registration prior to receiving a federal award, the applicant
must notify FEMA as soon as possible by contacting askcsid@fema.dhs.gov and providing the details of
the circumstances that prevent completion of these requirements. If FEMA determines there are exigent
circumstances and FEMA has decided to make an award, the applicant will be required to obtain a UEI
number, if applicable, and complete SAM registration within 30 days of the federal award date.
Electronic Delivery
FEMA is participating in the Grants.gov initiative to provide the grant community with a single site to
find and apply for grant funding opportunities. FEMA requires applicants to submit their initial
applications online through Grants.gov and to submit their final applications through ND Grants.
How to Register to Apply through Grants.gov
1. General Instructions: Registering and applying for an award under these programs is a multi-
step process and requires time to complete. Read the instructions below about registering to apply
for FEMA funds. Applicants should read the registration instructions carefully and prepare the
information requested before beginning the registration process. Reviewing and assembling the
required information before beginning the registration process will alleviate last-minute searches
for required information.
The registration process can take up to four weeks to complete. To ensure an application
meets the deadline, applicants are advised to start the required steps well in advance of their
submission.
Organizations must have a UEI number, an EIN, and an active SAM registration to apply for
grants. Organizations must also have a Grants.gov account to apply for an award under these
programs. Creating a Grants.gov account can be completed online in minutes, but UEI and SAM
registrations may take several weeks. Therefore, an organization’s registration should be done in
sufficient time to ensure it does not impact the entity’s ability to meet the required application
submission deadlines. Complete organizational instructions can be found on Grants.gov.
If individual applicants are eligible to apply for a grant funding opportunity, refer to
https://www.grants.gov/web/grants/applicants/registration.html to create an account with
Grants.gov.
2. Obtain a UEI Number: All entities applying for funding, including renewal funding, must have
a UEI number. Applicants must enter the UEI number in the applicable data entry field on the SF-
424 form.
For more detailed instructions for obtaining a UEI number, refer to SAM.gov.
3. Obtain Employer Identification Number: All entities applying for funding must provide an
EIN. The EIN can be obtained from the IRS by visiting: https://www.irs.gov/businesses/small-
businesses-self-employed/apply-for-an-employer-identification-number-ein-online.
4. Create a login.gov account: Applicants must have a login.gov account in order to register with
SAM or update their SAM registration. Applicants can create a login.gov account here:
Preparedness Grants Manual | May 2022 13
https://secure.login.gov/sign_up/enter_email?request_id=34f19fa8-14a2-438c-8323-
a62b99571fd3.
Applicants only have to create a login.gov account once. For applicants that are existing SAM
users, use the same email address for the login.gov account as with SAM.gov so that the two
accounts can be linked.
For more information on the login.gov requirements for SAM registration, refer to:
https://www.sam.gov/SAM/pages/public/loginFAQ.jsf.
5. Register with SAM: All organizations applying online through Grants.gov must register with
SAM. Failure to register with SAM will prevent your organization from applying through
Grants.gov. SAM registration must be renewed annually.
For more detailed instructions for registering with SAM, refer to
https://www.grants.gov/web/grants/applicants/organization-registration/step-2-register-with-
sam.html.
Note: As a new requirement per 2 C.F.R. § 25.200, applicants must also provide the applicant’s
immediate and highest-level owner, subsidiaries, and predecessors that have been awarded
federal contracts or federal financial assistance within the last three years, if applicable.
a. Additional SAM Reminders
Existing SAM.gov account holders should check their account to make sure it is “ACTIVE.”
SAM registration should be completed at the very beginning of the application period and
should be renewed annually to avoid being “INACTIVE.” Please allow plenty of time
before the grant application submission deadline to obtain a UEI number and then to
register in SAM. It may be four weeks or more after an applicant submits the SAM
registration before the registration is active in SAM, and then it may be an additional 24
hours before FEMA’s system recognizes the information.
It is imperative that the information applicants provide is correct and current. Please ensure
that your organization’s name, address, and EIN are up to date in SAM and that the UEI
number used in SAM is the same one used to apply for all other FEMA awards. Payment
under any FEMA award is contingent on the recipient’s having a current SAM registration.
b. Help with SAM
The SAM quick start guide for new recipient registration and SAM video tutorial for new
applicants are tools created by the General Services Administration to assist those registering
with SAM. If applicants have questions or concerns about a SAM registration, please contact
the Federal Support Desk at https://www.fsd.gov/fsd-gov/home.do or call toll free (866) 606-
8220.
6. Create a Grants.gov Account: The next step in the registration process is to create an account
with Grants.gov. Applicants must know their or their organization’s UEI number to complete this
process.
For more information, follow the on-screen instructions or refer to
https://www.grants.gov/web/grants/applicants/registration.html.
Preparedness Grants Manual | May 2022 14
7. Add a Profile to a Grants.gov Account: A profile in Grants.gov corresponds to a single
applicant organization the user represents (i.e., an applicant) or an individual applicant. If you
work for or consult with multiple organizations and have a profile for each, you may log in to one
Grants.gov account to access all of your grant applications. To add an organizational profile to
your Grants.gov account, enter the UEI number for the organization in the UEI field while adding
a profile.
For more detailed instructions about creating a profile on Grants.gov, refer to
https://www.grants.gov/web/grants/applicants/registration/add-profile.html.
8. EBiz Point of Contact (POC) Authorized Profile Roles: After you register with Grants.gov and
create an Organization Applicant Profile, the organization applicant’s request for Grants.gov roles
and access are sent to the EBiz POC. The EBiz POC will then log in to Grants.gov and authorize
the appropriate roles, which may include the AOR role, thereby giving you permission to
complete and submit applications on behalf of the organization. You will be able to submit your
application online any time after you have been assigned the AOR role.
For more detailed instructions about creating a profile on Grants.gov, refer to
https://www.grants.gov/web/grants/applicants/registration/authorize-roles.html.
9. Track Role Status: To track your role request, refer to
https://www.grants.gov/web/grants/applicants/registration/track-role-status.html.
10. Electronic Signature: When applications are submitted through Grants.gov, the name of the
organization applicant with the AOR role that submitted the application is inserted into the
signature line of the application, serving as the electronic signature. The EBiz POC must
authorize individuals who are able to make legally binding commitments on behalf of the
organization as an AOR. Please ensure you have been authorized by the EBiz POC as this step is
often missed, and it is crucial for valid and timely submissions.
How to Submit an Initial Application to DHS/FEMA via Grants.gov
Standard Form 424 (SF 424) is the initial application form.
Grants.gov applicants can apply online using a workspace. A workspace is a shared, online environment
where members of a grant team may simultaneously access and edit different web forms within an
application. For each NOFO, you can create individual instances of a workspace. Applicants are
encouraged to submit their initial applications in Grants.gov at least seven days before the application
deadline.
In Grants.gov, applicants need to submit the following forms:
• SF-424, Application for Federal Assistance; and
• Grants.gov Lobbying Form, Certification Regarding Lobbying.
Below is an overview of applying on Grants.gov. For access to complete instructions on how to apply for
opportunities using a workspace, refer to: https://www.grants.gov/web/grants/applicants/workspace-
overview.html
1. Create a Workspace: Creating a workspace allows you to complete it online and route it through
your organization for review before submitting.
Preparedness Grants Manual | May 2022 15
2. Complete a Workspace: Add participants to the workspace to work on the application together,
complete all the required forms online or by downloading PDF versions, and check for errors
before submission.
3. Adobe Reader: If you decide not to apply by filling out web forms, you can download individual
PDF forms in Workspace so that they will appear similar to other Standard or DHS/FEMA forms.
The individual PDF forms can be downloaded and saved to your local device storage, network
drive(s), or external drives, and then accessed through Adobe Reader.
NOTE: Visit the Adobe Software Compatibility page on Grants.gov to download the appropriate
version of the software at https://www.grants.gov/web/grants/applicants/adobe-software-
compatibility.html.
4. Mandatory Fields in Forms: In the forms, you will note fields marked with an asterisk and a
different background color. These fields are mandatory fields that must be completed to
successfully submit your application.
5. Complete SF-424 Fields First: The forms are designed to fill in common required fields across
other forms, such as the applicant name, address, and UEI number. To trigger this feature, an
applicant must complete the SF-424 information first. Once it is completed, the information will
transfer to the other forms.
6. Submit a Workspace: An application may be submitted through workspace by clicking the
“Sign and Submit” button on the Manage Workspace page, under the Forms tab. Grants.gov
recommends submitting your application package at least 24-48 hours prior to the close date to
provide you with time to correct any potential technical issues that may disrupt the application
submission.
7. Track a Workspace: After successfully submitting a workspace package, a Grants.gov Tracking
Number (GRANTXXXXXXXX) is automatically assigned to the application. The number will be
listed on the confirmation page that is generated after submission. Using the tracking number,
access the Track My Application page under the Applicants tab or the Details tab in the submitted
workspace.
Additional Training and Applicant Support: For additional training resources, including video
tutorials, refer to https://www.grants.gov/web/grants/applicants/applicant-training.html.
Grants.gov provides applicants 24/7 support (except federal holidays) via the toll-free number (800) 518-
4726 and email at support@grants.gov and the website at https://www.grants.gov/support.html. For
questions related to a specific grant contact the number listed in the NOFO of the grant for which you are
applying for.
If you are experiencing difficulties with your submission, it is best to call the Grants.gov Support Center
and get a ticket number. The Support Center ticket number will assist FEMA with tracking your issue and
understanding background information on the issue.
Submitting the Final Application in ND Grants
After submitting the initial application in Grants.gov, eligible applicants will be notified by FEMA and
asked to proceed with submitting their complete application package in ND Grants. Applicants can
register early with ND Grants and are encouraged to begin their ND Grants registration at the time of the
Preparedness Grants Manual | May 2022 16
NOFO announcement or, at the latest, seven days before the application deadline. Early registration will
allow applicants to have adequate time to start and complete their applications.
Applicants needing assistance registering for the ND Grants system should contact
ndgrants@fema.dhs.gov or (800) 865-4076. For step-by-step directions on using the ND Grants system
and other guides, please see https://www.fema.gov/grants/guidance-tools/non-disaster-grants-
management-system.
In ND Grants, applicants will be prompted to submit the standard application information required as
described in the “Content and Form of Application Submission” section below. The Standard Forms
(SFs) are auto-generated in ND Grants, but applicants may access these forms in advance through the
Forms tab under the SF-424 family on Grants.gov. Applicants should review these forms before applying
to ensure they have all the information required.
An application submitted by an otherwise eligible non-federal entity (i.e., the applicant) may be deemed
ineligible when the person that submitted the application is not: 1) a current employee, personnel,
official, staff, or leadership of the non-federal entity; and 2) duly authorized to apply for an award on
behalf of the non-federal entity at the time of application.
Further, the AOR and Signatory Authority (SA) must be a duly authorized current employee, personnel,
official, staff, or leadership of the recipient, and provide an email address unique to the recipient at the
time of application and upon any change in assignment during the period of performance. Consultants
or contractors of the recipient are not permitted to be the AOR or SA of the recipient.
For program-specific application submission requirements, please refer to the applicable program NOFO
and applicable appendix to this Manual.
Timely Receipt Requirements and Proof of Timely Submission
As application submission is a two-step process, the applicant with the AOR role who submitted the
application in Grants.gov will receive an acknowledgement of receipt, a tracking number
(GRANTXXXXXXXX) from Grants.gov with the successful transmission of its initial application. This
notification does not serve as proof of timely submission, as the application is not complete until it is
submitted in ND Grants. Applicants can also view the ND Grants Agency Tracking Number by
accessing the Details tab in the submitted workspace section in Grants.gov, under the Agency Tracking
Number column. Should the Agency Tracking Number not appear, the application has not yet migrated
from Grants.gov into the ND Grants system. Please allow 24 hours for your ND Grants application
tracking number to migrate.
All applications must be received in ND Grants by 5 p.m. ET on the application deadline. Proof of timely
submission is automatically recorded by ND Grants. An electronic date/time stamp is generated within
the system when the application is successfully received by ND Grants. Additionally, the applicant(s)
listed as contacts on the application will receive a system-generated email to confirm receipt.
Standard Required Application Forms and Information
For all programs, the following forms or information are required to be submitted in either Grants.gov or
ND Grants. The SFs are submitted either through Grants.gov, through forms generated in ND Grants, or
as an attachment in ND Grants. Applicants may also access the SFs at
https://www.grants.gov/web/grants/forms/sf-424-family.html.
Grants.gov:
Preparedness Grants Manual | May 2022 17
• SF-424, Application for Federal Assistance, initial application submitted through Grants.gov;
and
• Grants.gov Lobbying Form, Certification Regarding Lobbying, submitted through
Grants.gov.
ND Grants:
• SF-424A, Budget Information (Non-Construction), submitted via the forms generated by ND
Grants;
o For construction under an award, submit: SF-424C, Budget Information
(Construction), submitted via the forms generated by ND Grants, in addition to or
instead of SF-424A
• SF-424B, Standard Assurances (Non-Construction), submitted via the forms generated by ND
Grants;
o For construction under an award, submit: SF-424D, Standard Assurances
(Construction), submitted via the forms generated by ND Grants, in addition to or
instead of SF-424B
• SF-LLL, Disclosure of Lobbying Activities, submitted via the forms generated by ND Grants;
and
• Indirect Cost Agreement or Proposal, submitted as an attachment in ND Grants if the budget
includes indirect costs and the applicant is required to have an indirect cost rate agreement or
proposal. If the applicant does not have or is not required to have an indirect cost rate agreement
or proposal, please see the “Funding Restrictions and Allowable Costs” section in the relevant
program NOFO and the section below on indirect costs for further information regarding
allowability of indirect costs and whether alternatives to an indirect cost rate agreement or
proposal might be available or contact the relevant Preparedness Officer or Program Manager for
further instructions.
Generally, applicants have to submit either the non-construction forms (i.e., SF-424A and SF-424B) or
construction forms (i.e., SF-424C and SF-424D), meaning that applicants that only have construction
work and do not have any non-construction work need only submit the construction forms (i.e., SF-424C
and SF-424D) and not the non-construction forms (i.e., SF-424A and SF-424B), and vice versa. However,
applicants who have both construction and non-construction work under these programs need to submit
both the construction and non-construction forms.
Intergovernmental Review
An intergovernmental review may be required. Applicants must contact their state’s Single Point of
Contact to comply with the state’s process under Executive Order 12372.
See https://www.archives.gov/federal-register/codification/executive-order/12372.html;
https://www.whitehouse.gov/wp-content/uploads/2020/01/spoc_1_16_2020.pdf.
Funding Restrictions and Allowable Costs
All costs charged to awards covered by this Manual must comply with the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements at 2 C.F.R. Part 200, unless otherwise indicated
in this Manual, the applicable program NOFO, or the terms and conditions of the award. This includes,
among other requirements, that costs must be incurred, and products and services must be delivered,
within the period of performance of the award. See 2 C.F.R. § 200.403(h) (referring to budget periods,
which for FEMA preparedness grant awards is the same as the period of performance).
Federal funds made available through these awards may be used for the purposes set forth in this Manual,
the applicable program NOFO, and the terms and conditions of the award and must be consistent with the
Preparedness Grants Manual | May 2022 18
statutory authority for the award. Award funds may not be used for matching funds for any other federal
awards, lobbying, or intervention in federal regulatory or adjudicatory proceedings. In addition, federal
funds may not be used to sue the Federal Government or any other government entity.
In general, the Cost Principles establish standards for the allowability of costs, provide detailed guidance
on the cost accounting treatment of costs as direct or administrative costs, and set forth allowability
principles for selected items of cost. More specifically, except as otherwise stated in the applicable
program appendix to this Manual, the program NOFO, or the terms and condition of an award, costs
charged to awards covered by this Manual must be consistent with the Cost Principles for Federal Awards
located at 2 C.F.R. Part 200, Subpart E. In order to be allowable, all costs charged to a FEMA award or
applied to the cost share must be reasonable in nature and amount and allocable to the particular FEMA
award.
Additionally, all costs charged to awards must comply with the grant program’s applicable statutes,
policies, NOFOs, and requirements in this Manual and the applicable NOFO, as well as with the terms
and conditions of the award. If FEMA staff identify costs that are inconsistent with any of these
requirements, these costs may be disallowed, and FEMA may recover funds as appropriate, consistent
with applicable laws, regulations, and policies.
As part of those requirements, grant recipients and subrecipients may only use federal funds or funds
applied to a cost share for the purposes set forth in this Manual, applicable NOFOs, and the terms and
conditions of the award, and those costs and must be consistent with the statutory authority for the award.
Grant funds may not be used for matching funds for other federal grants/cooperative agreements,
lobbying, or intervention in federal regulatory or adjudicatory proceedings. In addition, federal funds may
not be used to sue the federal government or any other government entity.
Specific investments made in support of the funding priorities discussed in the appendices to this Manual
generally fall into one of the following eight allowable expense categories:
1. Construction;
2. Equipment;
3. Exercises;
4. Management & Administration (M&A);
5. Organization;
6. Operational Activities;
7. Planning; and
8. Training.
Please refer to the relevant program-specific appendix for more information on funding restrictions,
funding priorities, and these categories.
Accessibility Compliance
Preparedness grant program recipients using funds to build or alter buildings must comply with
accessibility requirements under the Rehabilitation Act of 1973 and Architectural Barriers Act of 1968
(ABA), as well as the Americans with Disabilities Act (ADA), if applicable, to ensure individuals with
disabilities have access to such buildings. Accessibility standards under the ABA and ADA are highly
similar. Additional information regarding compliance with the Architectural Barriers Act is available at
https://www.access-board.gov/aba/guides/chapter-1-using-the-aba-standards/#differences-between-the-
aba-and-ada-standards.
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Authorized Equipment List
The Authorized Equipment List (AEL) is a list of approved equipment types allowed under FEMA’s
preparedness grant programs. The intended audience of this tool is emergency managers, first responders,
and other homeland security professionals. The list consists of equipment categories divided into
categories, sub-categories, and then individual equipment items.
Prohibitions on Expending Grant or Cooperative Agreement Funds for Certain
Telecommunications and Video Surveillance Services or Equipment
Recipients and subrecipients of FEMA federal financial assistance are subject to the prohibitions
described in section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019
(FY 2019 NDAA), Pub. L. No. 115-232 (2018) and 2 C.F.R. §§ 200.216, 200.327, 200.471, and
Appendix II to 2 C.F.R. Part 200. Beginning August 13, 2020, the statute – as it applies to FEMA
recipients, subrecipients, and their contractors and subcontractors – prohibits obligating or expending
federal award funds on certain telecommunications and video surveillance products and contracting with
certain entities for national security reasons.
Guidance is available in FEMA Policy #405-143-1, Prohibitions on Expending FEMA Award Funds for
Covered Telecommunications Equipment or Services issued May 10, 2022.
Additional guidance is available at Contract Provisions Guide: Navigating Appendix II to Part 200 -
Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Effective August 13, 2020, FEMA recipients and subrecipients may not use any FEMA funds
under open or new awards to:
(1) Procure or obtain any equipment, system, or service that uses covered telecommunications
equipment or services as a substantial or essential component of any system, or as critical
technology of any system;
(2) Enter into, extend, or renew a contract to procure or obtain any equipment, system, or service
that uses covered telecommunications equipment or services as a substantial or essential
component of any system, or as critical technology of any system; or
(3) Enter into, extend, or renew contracts with entities that use covered telecommunications
equipment or services as a substantial or essential component of any system, or as critical
technology as part of any system.
Replacement Equipment and Services: FEMA grant funding may be permitted to procure replacement
equipment and services impacted by this prohibition, provided the costs are otherwise consistent with the
requirements in this Manual and the applicable NOFO.
Definitions
Per section 889(f)(2)-(3) of the FY 2019 NDAA and 2 C.F.R. § 200.216, covered telecommunications
equipment or services means:
i. Telecommunications equipment produced by Huawei Technologies Company or ZTE
Corporation, (or any subsidiary or affiliate of such entities);
ii. For the purpose of public safety, security of Government facilities, physical security
surveillance of critical infrastructure, and other national security purposes, video surveillance
and telecommunications equipment produced by Hytera Communications Corporation,
Preparedness Grants Manual | May 2022 20
Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any
subsidiary or affiliate of such entities);
iii. Telecommunications or video surveillance services provided by such entities or using such
equipment; or
iv. Telecommunications or video surveillance equipment or services produced or provided by an
entity that the Secretary of Defense, in consultation with the Director of National Intelligence
or the Director of the Federal Bureau of Investigation, reasonably believes to be an entity
owned or controlled by, or otherwise connected to, the People’s Republic of China.
Examples of the types of products covered by this prohibition include phones, internet, video
surveillance, and cloud servers when produced, provided, or used by the entities listed in the
definition of “covered telecommunications equipment or services.” See 2 C.F.R. § 200.471.
Preparedness Grants Manual | May 2022 21
Award Determination and Obligation
Allocations
Risk Methodology
DHS defines risk as: “potential for an adverse outcome assessed as a function of hazard/threats, assets and
their vulnerabilities, and consequences.” See DHS Lexicon Terms and Definitions: 2017 Edition –
Revision 2, (Oct. 2017). The FEMA risk methodology is focused on three elements:
• Threat: the likelihood of an attack being attempted by an adversary;
• Vulnerability: the likelihood that an attack is successful, given that it is attempted; and
• Consequence: the effect of an event, incident, or occurrence.
Please see the applicable appendix of this Manual for each award program for specific information on the
risk methodology applied for each program.
Application Evaluation Criteria
Programmatic Criteria
See the Manual appendices and relevant program NOFOs for specific information on the application
criteria specific to each program.
Financial Integrity Criteria
Prior to making a federal award, FEMA is required by 31 U.S.C. § 3354, as enacted by the Payment
Integrity Information Act of 2019, Pub. L. No. 116-117 (2020); 41 U.S.C. § 2313; and 2 C.F.R. § 200.206
to review information available through any Office of Management and Budget (OMB)-designated
repositories of governmentwide eligibility qualification or financial integrity information, including
whether the applicant is suspended or debarred. FEMA may also pose additional questions to the
applicant to aid in conducting the pre-award risk review. Therefore, application evaluation criteria may
include the following risk-based considerations of the applicant:
i. Financial stability;
ii. Quality of management systems and ability to meet management standards;
iii. History of performance in managing federal award;
iv. Reports and findings from audits; and
v. Ability to effectively implement statutory, regulatory, or other requirements.
All investments selected for recommendation will also undergo an additional risk review conducted by
the FEMA Grants Management Specialist to evaluate the risk for noncompliance in carrying out the
federal award. Using their subject-matter expertise, the questions the FEMA Grants Management
Specialist may assess include, but are not limited to:
• Is the applicant on any exclusion lists as identified in SAM.gov?
• If the applicant has received federal funding in the past, has the applicant performed all audits
required by the Single Audit requirements under 2 C.F.R. Part 200, Subpart F?
• Has the applicant provided sufficient budget information and justification as required by the
NOFO?
• Are the costs proposed by the applicant in the budget information and justification allowable and
reasonable based on the criteria set forth in this Manual and the applicable appendix, NOFO, and
regulations?
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• Is the budget representative of the total cost of performance of the projects?
• If indirect costs are included, is the applicant required to have an approved indirect cost rate
agreement? If so, has the applicant provided an approved indirect cost rate agreement?
• Is the applicant delinquent on any federal debt?
• Has the applicant had substandard performance in a prior award?
• Is the applicant on the Do Not Pay List?
Based on the outcome of this review, FEMA may determine that it will not make an award to an applicant
that poses a risk of noncompliance. FEMA may also determine that it will make an award to an at-risk
applicant, subject to additional terms and conditions as described in 2 C.F.R. § 200.208.
Supplemental Financial Integrity Review
Prior to making a federal award where the anticipated total federal share will be greater than the
simplified acquisition threshold, currently $250,000:
• FEMA is required to review and consider any information about the applicant, including
information on the applicant’s immediate and highest-level owner, subsidiaries, and predecessors,
if applicable, that is in the designated integrity and performance system accessible through SAM,
which is currently the Federal Awardee Performance and Integrity Information System (FAPIIS).
• An applicant, at its option, may review information in FAPIIS and comment on any information
about itself that a federal awarding agency previously entered.
• FEMA will consider any comments by the applicant, in addition to the other information in
FAPIIS, in making a judgment about the applicant’s integrity, business ethics, and record of
performance under federal awards when completing the review of risk posed by applicants, as
described in 2 C.F.R. § 200.206.
Review and Selection Process
FEMA will follow all applicable statutes, rules, and requirements and will take into consideration
materials accompanying the annual appropriations acts, such as the Joint Explanatory Statement, as
appropriate, in reviewing and selecting recipients.
Please see the applicable NOFO for the review and selection process for that program.
Federal Award Administration Information
Notice of Award
Before accepting the award, the AOR and recipient should carefully review the award package. The
award package includes instructions on administering the grant award and the terms and conditions
associated with responsibilities under federal awards. Recipients must accept all conditions in the
applicable program NOFO, as well as this Manual, in addition to any special terms and conditions
in the Notice of Award to receive an award under the applicable program.
Notification of award approval is made through the ND Grants system through an automatic electronic
mail to the recipient’s authorized official listed in the initial application. The award date will be the date
that FEMA approves the award. The recipient should follow the directions in the notification to confirm
acceptance of the award.
Recipients must accept their awards no later than 60 days from the award date. The recipient shall notify
FEMA of its intent to accept and proceed with work under the award or provide a notice of intent to
decline through the ND Grants system. For instructions on how to accept or decline an award in the ND
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Grants system, please see the Grant Recipient User Guide. Funds will remain on hold until the recipient
accepts the award through the ND Grants system and all other conditions of the award have been satisfied
or until the award is otherwise rescinded. Failure to accept a grant award within the 60-day timeframe
may result in a loss of funds.
Pass-Through Requirements
Please see the applicable NOFO and appendix to this Manual for information on pass-through
requirements for that program.
Administrative and National Policy Requirements
In addition to the requirements in this section and the applicable NOFO, FEMA may place specific terms
and conditions on individual awards in accordance with 2 C.F.R. Part 200.
All successful applicants for all FEMA grants and cooperative agreements are required to comply with
the DHS Standard Terms and Conditions.
The applicable DHS Standard Terms and Conditions will be those in effect at the time the award was
made. The specific terms and conditions that will apply for the award will be clearly stated in the award
package at the time of award.
Ensuring the Protection of Civil Rights
As the Nation works towards achieving the National Preparedness Goal, it is important to continue to
protect the civil rights of individuals. Recipients must carry out their programs and activities, including
those related to the building, sustainment, and delivery of core capabilities, in a manner that respects and
ensures the protection of civil rights for protected populations.
Federal civil rights statutes, such as Section 308 of the Stafford Act, Section 504 of the Rehabilitation Act
of 1973, and Title VI of the Civil Rights Act of 1964, Age Discrimination Act, along with DHS and
FEMA regulations, prohibit discrimination on the basis of race, color, national origin, sex, religion, age,
disability, limited English proficiency, or economic status in connection with programs and activities
receiving federal financial assistance from FEMA.
Recipients must complete the DHS Civil Rights Evaluation Tool within 30 days of receipt of the Notice
of Award. Information about this requirement and a fuller list of the civil rights provisions that apply to
recipients can be found in the DHS Standard Terms and Conditions. Additional information on civil rights
provisions is available at https://www.dhs.gov/civil-rights-resources-recipients-dhs-financial-assistance
and https://www.fema.gov/office-equal-rights.
Monitoring and oversight requirements in connection with recipient compliance with federal civil rights
laws are also authorized pursuant to 44 C.F.R Part 7.
In accordance with civil rights laws and regulations, recipients and subrecipients must ensure the consistent
and systematic fair, just, and impartial treatment of all individuals, including individuals who belong to
underserved communities that have been denied such treatment.
Environmental Planning and Historic Preservation (EHP) Compliance
As a federal agency, 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 FEMA, including grant-funded
projects, comply with federal EHP regulations, laws, and Executive Orders, as applicable.
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All non-critical new construction or substantial improvement of structures in a Special Flood Hazard Area
must, at a minimum, apply the flood elevations of the Federal Flood Risk Management Standard’s
Freeboard Value Approach unless doing so would cause the project to be unable to meet applicable
program cost-effectiveness requirements. All other types of projects may choose to apply the flood
elevations of the Federal Flood Risk Management Standard’s Freeboard Value Approach. See Executive
Order (EO) 14030, Climate-Related Financial Risk and FEMA Policy #-206-21-0003, Partial
Implementation of the Federal Flood Risk Management Standard for Hazard Mitigation Assistance
Programs (Interim) .
Recipients and subrecipients proposing projects that have the potential to impact the environment,
including, but not limited to, the construction of communication towers, modification or renovation
of existing buildings, structures, and facilities, new construction, including replacement of facilities,
and some training activities, must participate in the FEMA EHP review process. The EHP review
process involves the submission of a detailed project description along with any supporting
documentation requested by FEMA in order to determine whether the proposed project has the potential
to impact environmental resources or historic properties. A GPD EHP screening form and supporting
documentation for preparedness projects requiring EHP review should be submitted to
gpdehpinfo@fema.dhs.gov.
In some cases, FEMA is also 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; otherwise, FEMA may not be able to fund the project due to
noncompliance with EHP laws, Executive Orders, regulations, and policies.
DHS and FEMA EHP policy is found in directives and instructions available on Environmental and
Historic Preservation Guidance for FEMA Grant Applications, the FEMA website page that includes
documents regarding EHP responsibilities and program requirements, including implementation of the
National Environmental Policy Act and other EHP regulations and Executive Orders.
The GPD EHP screening form is located at https://www.fema.gov/media-library/assets/documents/90195.
Additionally, all recipients under this funding opportunity are required to comply with the FEMA GPD
EHP Policy Guidance, FEMA Policy #108-023-1, Grant Programs Directorate Environmental and
Historic Preservation Policy Guidance (July 28, 2018), available at https://www.fema.gov/media-
library/assets/documents/85376.
Executive Order (EO) 13985, Advancing Racial Equity and Support for Underserved Communities
through the Federal Government, rearticulates and strengthens the environmental justice framework
articulated in 1994 in EO 12898, Federal Actions to Address Environmental Justice in Minority
Populations and Low-Income Populations. Specifically, Section 1 of E.O. 13985 states that:
“Affirmatively advancing equity, civil rights, racial justice, and equal opportunity is the responsibility of
the whole of our Government. Because advancing equity requires a systemic approach to embedding
fairness in decision-making processes, executive departments and agencies…must recognize and work to
redress inequalities in their policies and programs that serve as barriers to equal opportunity.”
Many projects funded by GPD’s grant programs can have significant impacts on environmental justice. In
particular, construction of buildings and other structures and construction of new communication towers
may have disproportionately high and adverse effects on minority and low-income populations. FEMA
acknowledges the important role that FEMA recipients and subrecipients play in advancing and achieving
environmental justice by identifying low-income and minority populations within a proposed project’s
affected area as early as possible and taking steps to accommodate these interests.
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For consistency with the Administration’s policy, FEMA will review and evaluate potential projects for
racial equity and justice concerns. If FEMA determines that a proposed project would have a
disproportionately high and adverse effect on minority or low-income populations, FEMA will consult
with recipients and subrecipients to discuss the feasibility of revising the scope of work to avoid these
adverse impacts, or otherwise applying mitigation measures to alleviate these effects. In addition, FEMA
may work with other recipients and subrecipients to solicit public input on the proposed projects for a
more informed decision-making process. To learn more about how FEMA environmental justice
responsibilities might affect your project, go to https://www.fema.gov/fact-sheet/executive-order-12898-
environmental-justice.
National Incident Management System (NIMS) Implementation
NIMS guides all levels of government, nongovernmental organizations (NGO), and the private sector to
work together to prevent, protect against, mitigate, respond to, and recover from incidents. NIMS
provides stakeholders across the whole community with the shared vocabulary, systems, and processes to
successfully deliver the capabilities described in the National Preparedness System.
The NIMS Implementation Objectives for Local, State, Tribal, and Territorial Jurisdictions clarify the
NIMS implementation requirements in FEMA preparedness grant NOFO. As recipients and subrecipients
of federal preparedness (non-disaster) grant awards, jurisdictions and organizations must achieve, or be
actively working to achieve, all of the NIMS Implementation Objectives. The objectives can be found on
the NIMS webpage at https://www.fema.gov/emergency-managers/nims/implementation-training.
Emergency management and incident response activities require carefully managed resources (personnel,
teams, facilities, equipment, and/or supplies) to meet incident needs. NIMS defines a national,
interoperable approach for sharing resources, coordinating, and managing incidents, and communicating
information. Incident management refers to how incidents are managed across all homeland security
activities, including prevention, protection, mitigation, response, and recovery. Utilization of the
standardized resource management concepts such as typing, credentialing, and inventorying promote a
strong national mutual aid capability needed to support the delivery of core capabilities. Additional
information on resource management, NIMS resource typing definitions, job titles, and position
qualifications is available at https://www.fema.gov/emergency-managers/nims/components. Please also
see the individual program appendices in this Manual for additional requirements regarding NIMS
implementation for specific programs.
FEMA developed the NIMS Guideline for the National Qualification System to describe national
credentialing standards and to provide written guidance regarding the use of those standards. This
guideline describes credentialing and typing processes and identifies tools that Federal Emergency
Response Officials and emergency managers at all levels of government may use both routinely and to
facilitate multijurisdictional coordinated responses.
Although state (including territorial), local, tribal, and private sector partners (including nongovernmental
organizations) are not required to credential their personnel in accordance with these guidelines, FEMA
strongly encourages them to do so to leverage the federal investment in the Federal Information
Processing Standards 201 infrastructure and to facilitate interoperability for personnel deployed outside
their home jurisdiction.
Additional information about NIMS in general is available on FEMA’s website at
https://www.fema.gov/emergency-managers/nims.
The National Qualification System doctrine promotes interoperability by establishing a common language
for defining job titles and by enabling jurisdictions and organizations to plan for, request, and have
Preparedness Grants Manual | May 2022 26
confidence in the capabilities of personnel deployed for disasters and emergencies from other entities
through mutual aid agreements and compacts. Following the concepts and processes in this Guideline will
enhance national preparedness by expanding the network of qualified incident management and support
personnel who can be deployed nationwide.
Additional information about NIMS implementation is available at https://www.fema.gov/emergency-
managers/nims/implementation-training.
FirstNet
The Middle-Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, as amended (codified in
part at 47 U.S.C. §§ 1401-1473) established the First Responder Network Authority (hereinafter FirstNet
Authority) as an independent authority within the National Telecommunications and Information
Administration (NTIA). 47 U.S.C. § 1424(a). The FirstNet Authority’s statutory mission is to establish a
nationwide public safety broadband network (FirstNet). 47 U.S.C. § 1426(b). FirstNet uses the 700 MHz
D block spectrum to provide Long-Term Evolution (LTE)-based broadband services and applications to
public safety entities. 47 U.S.C. §§ 1401(2), 1421(a). FirstNet became operational in March 2018 and is
based on a single, national network architecture that evolves with technological advances and consists of
a physically separate evolved packet core (EPC) network and radio access networks (RANs).
FirstNet provides public safety entities with mission-critical broadband data capabilities and services
including, but not limited to messaging, image sharing, video streaming, group text, voice, data storage,
application, location-based services, and Quality of Service, Priority, and Preemption. Public safety
entities seeking to enhance their operational capabilities using broadband technology may seek grant
funding from appropriate programs to support the following:
• Planning for integration of information technology (IT) infrastructure, software, and site upgrades
necessary to connect to FirstNet
• Handheld broadband devices including smartphones, feature phones, tablets, wearables, push-to-
talk (PTT) devices
• Vehicle-mounted or otherwise field operated data devices, such as ruggedized laptops
• Network access devices, including portable Wi-Fi devices, Universal Serial Bus (USB)
modems/dongles, trunk-mounted modems, routers
• Customer-Owned and Managed (COAM) broadband deployable equipment, enabling public
safety to own and dispatch coverage expansion or capacity enhancement equipment within their
jurisdiction
• Broadband device accessories that enable efficient and safe public safety operations such as
headsets, belt clips, earpieces, remote Bluetooth sensors, ruggedized cases
• Subscriber Identification Modules (SIMs)/Universal Integrated Circuit Cards (UICCs) to allow
public safety users to update existing devices to operate on public safety prioritized services.
• One-time purchase and subscription-based applications for public safety use which could include,
among several other options, enterprise mobility management (EMM), mobile device
management (MDM), mobile Virtual Private Network (VPN), identity services, or cloud service
tools
As FirstNet is built out in all 56 states and territories, and coverage and capacity for first responders
expands, recipients are strongly encouraged to coordinate with the Statewide Interoperability Coordinator
(SWIC) and FirstNet on the planning, deployment timelines, and operational availability of the network
deployment within a specific state or territory, and to ensure that project does not conflict with network
planning efforts and complies with all technical requirements. FirstNet requires participating agencies to
demonstrate a subscription to public safety-prioritized broadband services to purchase FirstNet broadband
Preparedness Grants Manual | May 2022 27
devices or applications. Recipients must coordinate with FirstNet in advance of any strategic acquisition
of broadband LTE equipment to ensure that purchases adhere to all applicable standards for public safety
entities. Recipients with questions on FirstNet should contact info@firstnet.gov. Please also refer to the
most recent SAFECOM Guidance on Emergency Communications Grants for additional guidance.
SAFECOM Guidance Compliance
All entities using preparedness grant funding to support emergency communications investments are
required to comply with the SAFECOM Guidance on Emergency Communications Grants (SAFECOM
Guidance). The SAFECOM Guidance provides current information on emergency communications
policies, eligible costs, best practices, and technical standards for SLTT recipients investing federal funds
in emergency communications projects. It is also designed to promote and align with the National
Emergency Communications Plan (NECP). Conformance with the SAFECOM Guidance helps ensure
that federally funded investments are compatible, interoperable, resilient, and support national goals and
objectives for improving emergency communications. Applicants should use the SAFECOM Guidance
during planning, development, and implementation of emergency communications projects and in
conjunction with other planning documents (e.g., SCIPs). Specifically, Appendix D of the SAFECOM
Guidance contains compliance instructions for FEMA grant recipients.
Emergency communications investments also will be reviewed jointly by FEMA and the
Cybersecurity and Infrastructure Security Agency (CISA) to verify compliance with SAFECOM
Guidance. FEMA will coordinate directly with the recipient on any compliance concerns and will
provide technical assistance as necessary to help ensure full compliance.
Preparedness Grants Manual | May 2022 28
Post-Award Management and Implementation
Reporting
Recipients are required to submit various financial and programmatic reports as a condition of award
acceptance. Future awards and funds drawdown may be withheld if these reports are delinquent.
Consultants or contractors are not permitted to be the AOR or the SA of the recipient. The AOR, as the
Authorized Official for the award, is responsible for submitting programmatic and financial performance
reports, accepting award packages, signing assurances and certifications, and submitting award
amendments.
Federal Financial Reporting Requirements
Federal Financial Report (FFR)
Recipients must report obligations and expenditures to FEMA on a quarterly basis through the FFR form
(SF-425). Recipients may review the FFR Form (SF-425) at
https://www.grants.gov/web/grants/forms/post-award-reporting-forms.html#sortby=1. Recipients must
file the FFR electronically using the Payment and Reporting Systems (PARS).
Financial Reporting Periods and Due Dates
An FFR must be submitted quarterly throughout the period of performance (POP), including partial
calendar quarters, as well as in periods where no grant award activity occurs. The final FFR is due within
120 days after the end of the POP. Future awards and fund drawdowns may be withheld if these reports
are delinquent, demonstrate a lack of progress, or are insufficient in detail.
Except for the final FFR due at 120 days after the end of the POP for purposes of closeout, the following
reporting periods and due dates apply for the FFR:
FFR Reporting Period Report Due Date
October 1 – December 31 January 30
January 1 – March 31 April 30
April 1 – June 30 July 30
July 1 – September 30 October 30
Because of a system limitation, if at the end of the POP a recipient still has funds to draw down, PARS
requires an FFR be submitted within 30 days of the end of the POP in order to access those funds. In that
case, the recipient will need to submit an FFR within 30 days of the end of the POP in addition to the final
FFR within 120 days of the end of the POP. All other recipients who do not need to draw down funds
after the end of the POP are only required to submit the final FFR within 120 days after the end of the
POP.
Program Performance Reporting Requirements
Performance Progress Report (PPR)
Recipients are responsible for providing updated performance reports on a biannual basis as an
attachment in ND Grants. The PPR should include the following:
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• A brief narrative of overall project(s) status;
• A summary of project expenditures; and
• A description of any potential issues that may affect project completion
Note: This requirement does NOT apply to the EMPG Program, which has different performance
reporting requirements. These are described in the EMPG Program Appendix in this Manual.
Program Performance Reporting Periods and Due Dates
The following reporting periods and due dates apply for the PPR:
Reporting Period Report Due Date
January 1 – June 30 July 30
July 1 – December 31 January 30
Additional Programmatic Reporting Requirements and Information
Biannual Strategy Implementation Report (BSIR)2
In addition to the quarterly financial and biannual performance progress reports, recipients are responsible
for completing and submitting BSIRs through the Grants Reporting Tool (GRT). The BSIR is due within
30 days after the end of the reporting period: July 30 for the reporting period of January 1 through June 30
(summer BSIR report); and January 30 for the reporting period of July 1 through December 31 (winter
BSIR report). All required attributes of each project must be included. Updated obligations, expenditures,
and significant developments must be provided within the BSIR to show the progress of implementation
for every project as well as how expenditures support Planning, Organization, Equipment, Training, and
Exercises (POETE). The first BSIR will be due by January 30, or 30 days after the end of the first
reporting period of the award. Subsequent BSIR reports will require recipients to report on a project-by-
project basis.
Recipients also are responsible for completing and submitting a closeout BSIR. When an award’s POP or
the liquidation period ends in the middle of a reporting period, a “regular” BSIR must be submitted with
full accounting of actual project information/expenditures before a Closeout BSIR can be created/
submitted. The last “regular” BSIR is required because the Closeout BSIR does NOT contain full
functionality to edit any project information/expenditures. Once the last “regular” BSIR is approved by
GPD, the Closeout BSIR can be created/submitted. Please contact your HQ Preparedness Officer for
guidance on the information required for the Closeout BSIR.
Closeout Reporting Requirements
Within 120 days after the end of the POP for the prime award or after an amendment has been issued to
close out an award before the original POP ends, whichever occurs first, recipients must liquidate all
financial obligations and submit the following documentation in ND Grants:
1. The final request for payment, if applicable;
2. The final FFR (SF-425);
3. The final PPR;
2 BSIR requirements are applicable to the following grant programs: HSGP (SHSP, UASI, and OPSG), THSGP,
EMPG, and NSGP.
Preparedness Grants Manual | May 2022 30
4. A qualitative narrative summary of the impact of those accomplishments throughout the entire
POP submitted to the respective FEMA Preparedness Officer; and
5. Other documents required by program guidance, NOFOs, appendices to this Manual, terms and
conditions of the award, or other FEMA guidance.
In addition, any recipient that issues subawards to any subrecipient is responsible for closing out those
subawards as described in 2 C.F.R. § 200.344; subrecipients are still required to submit closeout materials
within 90 days of the subaward POP end date. When a subrecipient completes all closeout requirements,
pass-through entities must promptly complete all closeout actions for subawards in time for the recipient
to submit all necessary documentation and information to FEMA during the closeout of their prime
award.
After the prime award closeout reports have been reviewed and approved by FEMA, a closeout notice
will be completed to close out the grant. The notice will indicate the POP as closed, list any remaining
funds that will be deobligated, and address the requirement of maintaining the award records for at least
three years from the date of the final FFR. The record retention period may be longer than three years due
to an audit, litigation, for equipment or real property used beyond the period of performance or other
circumstances outlined in 2 C.F.R. § 200.334.
Recipients are responsible for refunding to FEMA any balances of unobligated cash that FEMA paid that
are not authorized to be retained per 2 C.F.R. § 200.344(d).
Administrative Closeout
Administrative closeout is a mechanism for FEMA to unilaterally move forward with closeout of an
award using available award information in lieu of final reports from the recipient per 2 C.F.R. §
200.344(h)-(i). It is a last resort available to FEMA, and if FEMA needs to administratively close an
award, this may negatively impact a recipient’s ability to obtain future funding. This mechanism can
also require FEMA to make cash or cost adjustments and ineligible cost determinations based on the
information it has, which may result in identifying a debt owed to FEMA by the recipient.
When a recipient is not responsive to FEMA’s reasonable efforts to collect required reports needed to
complete the standard closeout process, FEMA is required under 2 C.F.R. § 200.344(h) to start the
administrative closeout process within the regulatory timeframe. FEMA will make at least three written
attempts to collect required reports before initiating administrative closeout. If the recipient does not
submit all required reports in accordance with 2 C.F.R. § 200.344, the relevant program NOFO, this
Manual, and the terms and conditions of the award, FEMA must proceed to administratively close the
award with the information available within one year of the POP end date. Additionally, if the recipient
does not submit all required reports within one year of the POP end date, per 2 C.F.R. § 200.344(i),
FEMA must report in FAPIIS the recipient’s material failure to comply with the terms and conditions of
the award.
If FEMA administratively closes an award where no final FFR has been submitted, FEMA uses that
administrative closeout date in lieu of the final FFR submission date as the start of the three-year record
retention period under 2 C.F.R. § 200.334.
In addition, if an award is administratively closed, FEMA may decide to impose remedies for
noncompliance per 2 C.F.R. § 200.339, consider this information in reviewing future award applications,
or apply special conditions to existing or future awards.
Preparedness Grants Manual | May 2022 31
Disclosing Information per 2 C.F.R. § 180.335
This reporting requirement pertains to disclosing information related to government-wide suspension and
debarment requirements. Before a recipient enters into a grant award with FEMA, the recipient must
notify FEMA if it knows if it or any of the recipient’s principals under the award fall under one or more
of the four criteria listed at 2 C.F.R. § 180.335:
• Are presently excluded or disqualified;
• Have been convicted within the preceding three years of any of the offenses listed in 2 C.F.R. §
180.800(a) or had a civil judgment rendered against it or any of the recipient’s principals for one
of those offenses within that time period;
• Are presently indicted for or otherwise criminally or civilly charged by a governmental entity
(federal, state, or local) with commission of any of the offenses listed in 2 C.F.R. § 180.800(a); or
• Have had one or more public transactions (federal, state, or local) terminated within the preceding
three years for cause or default.
At any time after accepting the award, if the recipient learns that it or any of its principals falls under one
or more of the criteria listed at 2 C.F.R. § 180.335, the recipient must provide immediate written notice to
FEMA in accordance with 2 C.F.R. § 180.350.
Reporting of Matters Related to Recipient Integrity and Performance
Per 2 C.F.R. Part 200, Appendix I § F.3, the additional post-award reporting requirements in 2 C.F.R. Part
200, Appendix XII may apply to applicants who, if upon becoming recipients, have a total value of
currently active grants, cooperative agreements, and procurement contracts from all federal awarding
agencies that exceeds $10 million for any period of time during the POP of an award under these funding
opportunities.
Recipients that meet these criteria must maintain current information reported in FAPIIS about civil,
criminal, or administrative proceedings described in paragraph 2 of Appendix XII at the reporting
frequency described in paragraph 4 of Appendix XII.
Single Audit Report
For audits of fiscal years beginning on or after December 26, 2014, recipients that expend $750,000.00 or
more from all federal funding sources during their fiscal year are required to submit an organization-wide
financial and compliance audit report, also known as a “single audit” report.
The audit must be performed in accordance with the requirements of the U.S. Government Accountability
Office’s (GAO) Government Auditing Standards, located at https://www.gao.gov/yellowbook/overview,
and the requirements of Subpart F of 2 C.F.R. Part 200, located at http://www.ecfr.gov/cgi-bin/text-
idx?node=sp2.1.200.f.
Preparedness Grants Manual | May 2022 32
Additional Information
Monitoring and Oversight
Overview
Per 2 C.F.R. § 200.337, FEMA, through its authorized representatives, has the right, at all reasonable
times, to make site visits or conduct desk reviews to review project accomplishments and management
control systems in order to evaluate award progress and to provide any required technical assistance.
During site visits or desk reviews, FEMA will review recipients’ files related to the award. As part of any
monitoring and program evaluation activities, recipients must permit FEMA, upon reasonable notice, to
review grant-related records and to interview the organization’s staff and contractors regarding the
program. Recipients must respond in a timely and accurate manner to FEMA requests for information
relating to the award.
Effective monitoring and oversight help FEMA ensure that recipients use grant funds for their intended
purpose(s), verify that projects undertaken are consistent with approved plans, and ensure that recipients
make adequate progress towards stated goals and objectives. Additionally, monitoring serves as the
primary mechanism to ensure that recipients comply with applicable laws, rules, regulations, program
guidance, and requirements. FEMA regularly monitors all grant programs both financially and
programmatically in accordance with federal laws, regulations (including 2 C.F.R. Part 200), program
guidance, and the terms and conditions of the award. All monitoring efforts ultimately serve to evaluate
progress towards grant goals and proactively target and address issues that may threaten grant success
during the period of performance.
FEMA staff will periodically monitor recipients to ensure that administrative processes, policies and
procedures, budgets, and other related award criteria are meeting Federal Government-wide and FEMA
regulations. Aside from reviewing quarterly financial and programmatic reports, FEMA may also conduct
enhanced monitoring through desk-based reviews, onsite monitoring visits, or both. Enhanced monitoring
will involve the review and analysis of financial compliance and administrative processes, policies,
activities, and other attributes of each federal assistance award, and it will identify areas where the
recipient may need technical assistance, corrective actions, or other support.
Financial and programmatic monitoring are complementary processes within FEMA’s overarching
monitoring strategy that function together to ensure effective grants management, accountability, and
transparency; validate progress against grant and program goals; and safeguard federal funds against
fraud, waste, and abuse. Financial monitoring primarily focuses on statutory and regulatory compliance
with administrative grant requirements, while programmatic monitoring seeks to validate and assist in
grant progress, targeting issues that may be hindering project goals and ensuring compliance with the
purpose of the grant and grant program. Both monitoring processes are similar in that they feature initial
reviews of all open awards, and in-depth monitoring of grants requiring additional attention.
Recipients and subrecipients who are pass-through entities are responsible for monitoring their
subrecipients in a manner consistent with the terms of the federal award at 2 C.F.R. Part 200, including 2
C.F.R. § 200.332. This includes the pass-through entity’s responsibility to monitor the activities of the
subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with
federal statutes, regulations, and the terms and conditions of the subaward; and that subaward
performance goals are achieved.
In terms of overall award management, recipient and subrecipient responsibilities include, but are not
limited to accounting of receipts and expenditures, cash management, maintaining adequate financial
Preparedness Grants Manual | May 2022 33
records, reporting, and refunding expenditures disallowed by audits, monitoring if acting as a pass-
through entity, other assessments and reviews, and ensuring overall compliance with the terms and
conditions of the award or subaward, as applicable, including the terms of 2 C.F.R. Part 200.
Financial Monitoring Overview and Approach
FEMA’s approach to financial monitoring provides a standard monitoring framework that promotes
consistent processes across all monitoring staff. There are four core components of the monitoring
process:
1. Monitoring Assessment: Monitoring staff measure each grant’s monitoring needs using a system
of pre-determined evaluation criteria. The criteria help assess the recipient and potential
challenges to the success of the grant award.
2. Monitoring Selection and Scheduling: Monitoring staff make selection and scheduling
decisions in accordance with applicable statutory requirements, such as the Homeland Security
Act of 2002, as amended (hereafter “HSA”), and consider the results of the monitoring assessment
process.
3. Monitoring Activities: Monitoring activities include cash analysis, desk reviews, and site visits.
Grants Management Specialists are responsible for conducting quarterly or semi-annual reviews
of all grants via cash analysis. Desk reviews and site visits are additional monitoring activities
conducted on grants where the monitoring assessment process identified the need for additional
monitoring and validated the use of FEMA resources for these activities.
4. Post-Monitoring Actions: Monitoring staff may follow up with recipients via post-monitoring
actions based on the outcomes of monitoring activities. Post-monitoring actions include
conducting additional monitoring; reviewing Corrective Action Plans (CAP) and monitoring the
progress of CAP deliverables; documenting the resolution of identified corrective actions and
issues; providing technical assistance and recipient training; and debt collection.
In addition to the monitoring guidance outlined above, section 2022(a)(2)(A) of the HSA mandates the
frequency of monitoring activities for applicable preparedness grants. The applicable section of the HSA
reads as follows:
Not less than once every 2 years, the Administrator shall conduct, for each state and high-risk
urban area receiving a grant administered by the Department, a programmatic and financial
review of all grants awarded by the Department to prevent, prepare for, protect against, or
respond to natural disasters, acts of terrorism, or other man-made disasters, excluding assistance
provided under section 203, title IV, or title V of the Robert T. Stafford Disaster Relief and
Emergency Assistance Act (42 U.S.C. 5133, 5170 et seq., and 5191 et seq.).
The following preparedness grant programs covered by this Manual are subject to HSA monitoring
requirements:
• HSGP
o SHSP
o UASI
o OPSG
• NSGP
• TSGP
Preparedness Grants Manual | May 2022 34
• PSGP
• EMPG Program
Standard Monitoring Activity: Cash Analysis
Through cash analysis, a Grants Management Specialist assesses and reports on the recipients’ cash-on-
hand, expenditures, and unliquidated obligations; gauges potential cost share shortfalls; cash on hand
issues; and spend down activities within the POP. The analysis reconciles and compares grant
disbursement records with the recipient submitted FFR. This process identifies recipients that may require
additional monitoring due to issues identified with drawdowns or FFR submissions.
Enhanced Monitoring Activities: Desk Review, Site Visit
Desk reviews and site visits are two forms of additional monitoring that FEMA conducts on a recipient.
Table 1 defines the key differences and similarities.
Table 1 - Enhanced Financial Monitoring Activities (Desk Review and Site Visit)
Attribute Desk Review Site Visit
Location/
Logistics
A detailed, paper-based review and
evaluation conducted at a FEMA office.
Desk reviews do not require travel.
A visit by FEMA grants management staff
conducted at the site of the recipient’s
operations and/or selected performance
sites. Site visits may require travel.
Materials
Reviewed
Required reports, correspondence, and
other documentation, including policies
and procedures, to substantiate
compliance. Additional documentation
available remotely may include
information available through the grant
file, financial reports, interviews, and
other documentation and correspondence
to verify compliance.
Includes documents listed under the desk
review in addition to all applicable
documents and required reports necessary
to assess recipient capability and progress,
validate records, and substantiate
compliance with laws, regulations, and
policies.
Goal of
Monitoring
Activity
The goals of FEMA’s financial desk
review monitoring activities are, as
applicable, to:
• Review grant files to verify
compliance, conduct interviews to
confirm adherence to approved
program plans, and confirm
equipment acquisition, allowable
use, and inventory controls;
• Document that recipient
institutions possess adequate
internal controls, policies,
processes, and systems to manage
FEMA grants effectively;
• Assist the recipient with the grant
process and provide guidance to
improve recipient administrative
efficiencies;
• Identify and analyze relevant
The goals of FEMA’s financial site visit
monitoring activities are, as applicable, to:
• Review grant files to verify
compliance, conduct interviews to
confirm adherence to approved
program plans, and confirm
equipment acquisition, allowable
use, and inventory controls;
• Document that recipient institutions
possess adequate internal controls,
policies, processes, and systems to
manage FEMA grants effectively;
• Assist the recipient with the grant
process and provide guidance to
improve recipient administrative
efficiencies;
• Identify and analyze relevant
problems that might prevent the
program from achieving its
Preparedness Grants Manual | May 2022 35
Attribute Desk Review Site Visit
problems that might prevent the
program from achieving its
internal and external objectives;
and
• Provide technical assistance.
internal and external objectives;
and
• Provide technical assistance.
Programmatic Monitoring Overview and Approach
Programmatic monitoring involves oversight throughout the award lifecycle in order for FEMA to verify
that programs and projects undertaken by recipients are consistent with approved plans and comply with
applicable laws, regulations, program guidance, and the terms and conditions of the award.
FEMA’s monitoring approach complies with the monitoring requirements described in section 2022 of
the HSA. Programmatic monitoring also plays an important role in ensuring that FEMA preparedness
grant funding builds and sustains capabilities at the SLTT levels that advance the National Preparedness
Goal. Programmatic monitoring also is an opportunity for FEMA staff to build relationships with
recipients and to work collaboratively to identify and mitigate factors that may impede programmatic
performance.
Programs covered by this Manual that are included in the programmatic monitoring approach are listed
below, including the programs subject to section 2022 of the HSA and three additional programs
(THSGP, IPR, and IBSGP):
• HSGP
o SHSP
o UASI
o OPSG
• NPSG
• THSGP
• TSGP
• IPR
• IBSGP
• PSGP
• EMPG Program
FEMA uses a risk- and project-based programmatic monitoring framework for its preparedness grant
programs that is designed for data-driven grants management, and which interacts seamlessly with other
aspects of the grant lifecycle. FEMA uses monitoring as a vehicle to validate data previously self-reported
by recipients in applications and reporting tools. FEMA does not utilize monitoring as a data collection
tool in and of itself. By specializing monitoring in this way, FEMA avoids duplicative data collection,
targets its resources more effectively, and provides stronger and more proactive technical assistance to its
recipients. The framework also comprehensively documents grant management decisions for resource
allocation.
This programmatic monitoring approach establishes baseline monitoring of all open awards across the
FEMA preparedness grant portfolio using a First Line Review (FLR). The FLR identifies recipients and
awards with a high potential for noncompliance with regulations or failure to meet project objectives. The
FLR uses quantifiable measures (criteria) to prioritize and rank recipients and awards according to
identified risks that threaten the success of FEMA’s preparedness grant awards. Results of this
prioritization process determine which high-risk recipients and awards will receive advanced monitoring.
Preparedness Grants Manual | May 2022 36
Post-monitoring actions document and communicate findings and recommendations for resolution to the
recipients and FEMA leadership and allow for increasingly cohesive programmatic and financial
monitoring processes.
Case Studies and Use of Grant-Funded Resources During Real-World
Incident Operations
Analyzing the use of grant-funded investments in real-world incidents will improve the ability of FEMA
and its SLTT partners to assess the effectiveness of these investments and to better understand how grant
funds support improvements in nationwide capability levels. Currently, FEMA conducts case studies with
a limited number of grant recipients each year to explore how jurisdictions prioritize grant investments
based on risk and capability assessments, and the ways specific investments improve SLTT preparedness
(https://www.fema.gov/grants/preparedness/about/case-studies). By accepting the award, the recipient
agrees to participate in a case study or evaluation if requested.
Termination Provisions
FEMA may terminate a federal award in whole or in part for one of the following reasons. FEMA and the
recipient must still comply with closeout requirements at 2 C.F.R. §§ 200.344-200.345 even if an award is
terminated in whole or in part. To the extent that subawards are permitted under the respective program’s
NOFO, pass-through entities should refer to 2 C.F.R. § 200.340 for additional information on termination
regarding subawards.
1. Noncompliance. If an applicant fails to comply with the terms and conditions of a federal award,
FEMA may terminate the award in whole or in part. If the noncompliance can be corrected,
FEMA may first attempt to direct the recipient to correct the noncompliance. This may take the
form of a Compliance Notification. If the noncompliance cannot be corrected or the recipient is
non-responsive, FEMA may proceed with a Remedy Notification, which could impose a remedy
for noncompliance per 2 C.F.R. § 200.339, including termination. Any action to terminate based
on noncompliance will follow the requirements of 2 C.F.R. §§ 200.341-200.342 as well as the
requirement of 2 C.F.R. § 200.340(c) to report in FAPIIS the recipient’s material failure to
comply with the award terms and conditions. See also the section on Actions to Address
Noncompliance.
2. With the Consent of the Recipient. FEMA may also terminate an award in whole or in part with
the consent of the recipient, in which case the parties must agree upon the termination
conditions, including the effective date, and in the case of partial termination, the portion to be
terminated.
3. Notification by the Recipient. The recipient may terminate the award, in whole or in part, by
sending written notification to FEMA setting forth the reasons for such termination, the effective
date, and in the case of partial termination, the portion to be terminated. In the case of partial
termination, FEMA may determine that a partially terminated award will not accomplish the
purpose of the federal award, so FEMA may terminate the award in its entirety. If that occurs,
FEMA will follow the requirements of 2 C.F.R. §§ 200.341-200.342 in deciding to fully
terminate the award.
Period of Performance (POP) Extensions
Extensions to the POP for programs addressed in this Manual are allowed under limited circumstances.
Extensions to the initial POP identified in the award will only be considered through formal, written
requests to the recipient’s FEMA Preparedness Officer or Program Manager and must contain specific
Preparedness Grants Manual | May 2022 37
and compelling justifications as to why an extension is required. Recipients are advised to coordinate with
their FEMA Preparedness Officer or Program Manager as needed when preparing an extension request.
All extension requests must address the following:
1. The grant program, fiscal year, and award number;
2. Reason for the delay–including details of the legal, policy, or operational challenges that prevent
the final outlay of awarded funds by the deadline;
3. Current status of the activity(ies);
4. Approved POP termination date and new project completion date;
5. Amount of funds drawn down to date;
6. Remaining available funds, both federal and, if applicable, non-federal;
7. Budget outlining how remaining federal and, if applicable, non-federal funds will be expended;
8. Plan for completion, including milestones and timeframes for achieving each milestone and the
position or person responsible for implementing the plan for completion; and
9. Certification that the activity(ies) will be completed within the extended POP without any
modification to the original statement of work, as described in the investment justification and as
approved by FEMA.
Extension requests will be granted only due to compelling legal, policy, or operational challenges.
Extension requests will only be considered for the following reasons:
• Contractual commitments by the recipient or subrecipient with vendors prevent completion of the
project within the existing POP;
• The project must undergo a complex environmental review that cannot be completed
within the existing POP;
• Projects are long-term by design, and therefore acceleration would compromise core
programmatic goals; or
• Where other special or extenuating circumstances exist.
Recipients should submit all proposed extension requests to FEMA for review and approval at least 120
days prior to the end of the POP to allow sufficient processing time. Extensions are typically granted for
no more than a six-month period. Recipients are advised to coordinate with their FEMA Preparedness
Officer or Program Manager as needed when preparing an extension request.
Disability Integration
Pursuant to Section 504 of the Rehabilitation Act of 1973, recipients of FEMA financial assistance must
ensure that their programs and activities do not discriminate against other qualified individuals with
disabilities.
Preparedness grant recipients should engage with the whole community to advance individual and
community preparedness and to work as a nation to build and sustain resilience. In doing so, recipients
are encouraged to consider the needs of individuals with disabilities into the activities and projects funded
by the grant.
FEMA expects that the integration of the needs of people with disabilities will occur at all levels,
including planning; alerting, notification, and public outreach; training; purchasing of equipment and
supplies; protective action implementation; and exercises/drills.
Preparedness Grants Manual | May 2022 38
The following are examples that demonstrate the integration of the needs of people with disabilities in
carrying out FEMA awards:
• Include representatives of organizations that work with/for people with disabilities on planning
committees, work groups and other bodies engaged in development and implementation of the
grant programs and activities.
• Hold all activities related to the grant in locations that are accessible to persons with physical
disabilities to the extent practicable.
• Acquire language translation services, including American Sign Language, that provide public
information across the community and in shelters.
• Ensure shelter-specific grant funds are in alignment with FEMA’s Guidance on Planning for
Integration of Functional Needs Support Services in General Population Shelters.
• If making alterations to an existing building to a primary function area utilizing federal funds,
complying with the most recent codes and standards, and making path of travel to the primary
function area accessible to the greatest extent possible.
• Implement specific procedures used by public transportation agencies that include evacuation and
passenger communication plans and measures for individuals with disabilities.
• Identify, create, and deliver training to address any training gaps specifically aimed toward
whole-community preparedness. Include and interact with individuals with disabilities, aligning
with the designated program capability.
• Establish best practices in inclusive planning and preparedness that consider physical access,
language access, and information access. Examples of effective communication access include
providing auxiliary aids and services such sign language interpreters, Computer Aided Real-time
Translation (CART), and materials in Braille or alternate formats.
FEMA grant recipients can fund projects towards the resiliency of the whole community, including
people with disabilities, such as training, outreach, and safety campaigns, provided that the project aligns
with the applicable NOFO, this Manual, the applicable appendix to this Manual, and the terms and
conditions of the award. For specific guidelines on funding a disability inclusive project, please refer to
the program-specific appendix in this Manual.
Conflicts of Interest in the Administration of Federal Awards or
Subawards
For conflicts of interest under grant-funded procurements and contracts, refer to the section on
Procurement Integrity in the applicable NOFO, this Manual, and 2 C.F.R. §§ 200.317 – 200.327.
To eliminate and reduce the impact of conflicts of interest in the subaward process, recipients and pass-
through entities must follow their own policies and procedures regarding the elimination or reduction of
conflicts of interest when making subawards. Recipients and pass-through entities are also required to
follow any applicable federal or SLTT statutes or regulations governing conflicts of interest in the making
of subawards.
The recipient or pass-through entity must disclose to the respective Preparedness Officer or Program
Manager, in writing, any real or potential conflict of interest that may arise during the administration of
the federal award, as defined by the federal or SLTT statutes or regulations or their own existing policies,
within five days of learning of the conflict of interest. Similarly, subrecipients, whether acting as
subrecipients or as pass-through entities, must disclose any real or potential conflict of interest to the
Preparedness Grants Manual | May 2022 39
recipient or next-level pass-through entity as required by the recipient or pass-through entity’s conflict of
interest policies, or any applicable federal or SLTT statutes or regulations.
Conflicts of interest may arise during the process of FEMA making a federal award in situations where an
employee, officer, or agent, any members of his or her immediate family, his or her partner has a close
personal relationship, a business relationship, or a professional relationship, with an applicant,
subapplicant, recipient, subrecipient, or FEMA employees.
Procurement Integrity
Through audits conducted by the DHS Office of Inspector General (OIG) and FEMA grant monitoring,
findings have shown that some FEMA recipients have not fully adhered to the proper procurement
requirements when spending grant funds. Anything less than full compliance with federal procurement
requirements jeopardizes the integrity of the grant, as well as the grant program. To assist with
determining whether an action is a procurement or instead a subaward, please consult 2 C.F.R § 200.331.
For detailed guidance on the federal procurement standards, recipients and subrecipients should refer to
various materials issued by FEMA’s Procurement Disaster Assistance Team (PDAT), such as the PDAT
Field Manual and Contract Provisions Guide. Additional resources, including an upcoming trainings
schedule, can be found on the PDAT Website: https://www.fema.gov/grants/procurement.
The below highlights the federal procurement requirements for FEMA recipients when procuring goods
and services with federal grant funds. FEMA will include a review of recipients’ procurement practices as
part of the normal monitoring activities. All procurement activity must be conducted in accordance
with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. Select requirements under
these standards are listed below. The recipient and any of its subrecipients must comply with all
requirements, even if they are not listed below.
Under 2 C.F.R. § 200.317, when procuring property and services under a federal award, states (including
territories) must follow the same policies and procedures they use for procurements from their non-federal
funds; additionally, states must now follow 2 C.F.R. § 200.321 regarding socioeconomic steps, § 200.322
regarding domestic preferences for procurements, § 200.323 regarding procurement of recovered
materials, and § 200.327 regarding required contract provisions.
All other non-federal entities, such as tribes (collectively, non-state entities), must have and use their
own documented procurement procedures that reflect applicable SLTT laws and regulations, provided
that the procurements conform to applicable federal law and the standards identified in 2 C.F.R. Part 200.
These standards include, but are not limited to, providing for full and open competition consistent with
the standards of 2 C.F.R. § 200.319 and § 200.320.
Important Changes to Procurement Standards in 2 C.F.R Part 200
OMB recently updated various parts of Title 2 of the Code of Federal Regulations, among them, the
procurement standards. States are now required to follow the socioeconomic steps in soliciting small and
minority businesses, women’s business enterprises, and labor surplus area firms per 2 C.F.R. § 200.321.
All non-federal entities should also, to the greatest extent practicable under a federal award, provide a
preference for the purchase, acquisition, or use of goods, products, or materials produced in the United
States per 2 C.F.R. § 200.322. More information on OMB’s revisions to the federal procurement
standards can be found in Purchasing Under a FEMA Award: OMB Revisions Fact Sheet.
The recognized procurement methods in 2 C.F.R. § 200.320 have been reorganized into informal
procurement methods, which include micro-purchases and small purchases; formal procurement methods,
Preparedness Grants Manual | May 2022 40
which include sealed bidding and competitive proposals; and noncompetitive procurements. The federal
micro-purchase threshold is currently $10,000, and non-state entities may use a lower threshold when
using micro-purchase procedures under a FEMA award. If a non-state entity wants to use a micro-
purchase threshold higher than the federal threshold, it must follow the requirements of 2 C.F.R. §
200.320(a)(1)(iii)-(v). The federal simplified acquisition threshold is currently $250,000, and a non-state
entity may use a lower threshold but may not exceed the federal threshold when using small purchase
procedures under a FEMA award. See 2 C.F.R. § 200.1 (citing the definition of simplified acquisition
threshold from 48 C.F.R. Part 2, Subpart 2.1).
See 2 C.F.R. §§ 200.216, 200.471, and Appendix II as well as FEMA Policy #405-143-1, Prohibitions on
Expending FEMA Award Funds for Covered Telecommunications Equipment or Services (May 10, 2022),
the relevant program NOFO, and this Manual regarding prohibitions on covered telecommunications
equipment or services.
Competition and Conflicts of Interest
Among the requirements of 2 C.F.R. § 200.319(b) applicable to all non-federal entities other than states,
contractors that develop or draft specifications, requirements, statements of work, or invitations for bids
or requests for proposals must be excluded from competing for such procurements in order to ensure
objective contractor performance and eliminate unfair competitive advantages. FEMA considers these
actions to be an organizational conflict of interest and interprets this restriction as applying to contractors
that help a non-federal entity develop its grant application, project plans, or project budget. This
prohibition also applies to the use of former employees to manage the grant or carry out a contract when
those former employees worked on such activities while they were employees of the non-federal entity.
Under this prohibition, unless the non-federal entity solicits for and awards a contract covering both
development and execution of specifications (or similar elements as described above), and this contract
was procured in compliance with 2 C.F.R. §§ 200.317 – 200.327, federal funds cannot be used to pay a
contractor to carry out the work if that contractor also worked on the development of those specifications.
This rule applies to all contracts funded with federal grant funds, including pre-award costs, such as grant
writer fees, as well as post-award costs, such as grant management fees.
Additionally, some of the situations considered to be restrictive of competition include but are not limited
to:
• Placing unreasonable requirements on firms in order for them to qualify to do business;
• Requiring unnecessary experience and excessive bonding;
• Noncompetitive pricing practices between firms or between affiliated companies;
• Noncompetitive contracts to consultants that are on retainer contracts;
• Organizational conflicts of interest;
• Specifying only a “brand name” product instead of allowing “an equal” product to be offered and
describing the performance or other relevant requirements of the procurement; and
• Any arbitrary action in the procurement process.
Per 2 C.F.R. § 200.319(c), non-federal entities other than states must conduct procurements in a manner
that prohibits the use of statutorily or administratively imposed SLTT geographical preferences in the
evaluation of bids or proposals, except in those cases where applicable federal statutes expressly mandate
or encourage geographic preference. Nothing in this section preempts state licensing laws. When
contracting for architectural and engineering services, geographic location may be a selection criterion
provided its application leaves an appropriate number of qualified firms, given the nature and size of the
project, to compete for the contract.
Preparedness Grants Manual | May 2022 41
Under 2 C.F.R. § 200.318(c)(1), non-federal entities other than states are required to maintain written
standards of conduct covering conflicts of interest and governing the actions of their employees engaged
in the selection, award, and administration of contracts. No employee, officer, or agent may participate
in the selection, award, or administration of a contract supported by a federal award if he or she
has a real or apparent conflict of interest. Such conflicts of interest would arise when the employee,
officer, or agent, any member of his or her immediate family, his or her partner, or an organization that
employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a
tangible personal benefit from a firm considered for a contract. The officers, employees, and agents of the
non-federal entity may neither solicit nor accept gratuities, favors, or anything of monetary value from
contractors or parties to subcontracts. However, non-federal entities may set standards for situations in
which the financial interest is not substantial, or the gift is an unsolicited item of nominal value. The
standards of conduct must provide for disciplinary actions to be applied for violations of such standards
by officers, employees, or agents of the non-federal entity.
Under 2 C.F.R. § 200.318(c)(2), if the recipient or subrecipient (other than states) has a parent, affiliate,
or subsidiary organization that is not a state, local, tribal, or territorial government, the non-federal entity
must also maintain written standards of conduct covering organizational conflicts of interest. In this
context, organizational conflict of interest means that because of a relationship with a parent company,
affiliate, or subsidiary organization, the non-federal entity is unable or appears to be unable to be
impartial in conducting a procurement action involving a related organization. The non-federal entity
must disclose in writing any potential conflicts of interest to FEMA or the pass-through entity in
accordance with applicable FEMA policy.
Supply Schedules and Purchasing Programs
Generally, a non-federal entity may seek to procure goods or services from a federal supply schedule,
state supply schedule, or group purchasing agreement.
General Services Administration Schedules
States, tribes, and local governments, and any instrumentality thereof (such as local education agencies or
institutions of higher education), may procure goods and services from a General Services Administration
(GSA) schedule. GSA offers multiple efficient and effective procurement programs for state, tribal, and
local governments, and instrumentalities thereof, to purchase products and services directly from pre-
vetted contractors. The GSA Schedules (also referred to as the Multiple Award Schedules and the Federal
Supply Schedules) are long-term government-wide contracts with commercial firms that provide access to
millions of commercial products and services at volume discount pricing.
Information about GSA programs for states, tribes, and local governments, and instrumentalities thereof,
can be found at https://www.gsa.gov/resources-for/programs-for-State-and-local-governments and
https://www.gsa.gov/buying-selling/purchasing-programs/gsa-schedules/schedule-buyers/state-and-local-
governments.
For tribes, local governments, and their instrumentalities that purchase off of a GSA schedule, this will
satisfy the federal requirements for full and open competition provided that the recipient follows the GSA
ordering procedures; however, tribes, local governments, and their instrumentalities will still need to
follow the other rules under 2 C.F.R. §§ 200.317 – 200.327, such as solicitation of minority businesses,
women’s business enterprises, small businesses, or labor surplus area firms (§ 200.321), domestic
preferences (§ 200.322), contract cost and price (§ 200.324), and required contract provisions (§ 200.327
and Appendix II).
Preparedness Grants Manual | May 2022 42
Other Supply Schedules and Programs
For non-federal entities other than states, such as tribes, local governments, and nonprofits, that want to
procure goods or services from a state supply schedule, cooperative purchasing program, or other similar
program, in order for such procurements to be permissible under federal requirements, the following must
be true:
• The procurement of the original contract or purchasing schedule and its use by the non-federal
entity complies with state and local law, regulations, and written procurement procedures;
• The state or other entity that originally procured the original contract or purchasing schedule
entered into the contract or schedule with the express purpose of making it available to the non-
federal entity and other similar types of entities;
• The contract or purchasing schedule specifically allows for such use, and the work to be
performed for the non-federal entity falls within the scope of work under the contract as to type,
amount, and geography;
• The procurement of the original contract or purchasing schedule complied with all the
procurement standards applicable to a non-federal entity other than states under at 2 C.F.R. §§
200.317 – 200.327; and
• With respect to the use of a purchasing schedule, the non-federal entity must follow ordering
procedures that adhere to applicable state, tribal, and local laws and regulations and the minimum
requirements of full and open competition under 2 C.F.R. Part 200.
If a non-federal entity other than a state seeks to use a state supply schedule, cooperative purchasing
program, or other similar type of arrangement, FEMA recommends the recipient discuss the procurement
plans with its FEMA Preparedness Officer or Program Manager.
Procurement Documentation
Per 2 C.F.R. § 200.318(i), non-federal entities other than states and territories are required to maintain and
retain records sufficient to detail the history of procurement covering at least the rationale for the
procurement method, contract type, contractor selection or rejection, and the basis for the contract price.
States and territories are encouraged to maintain and retain this information as well and are reminded that
in order for any cost to be allowable, it must be adequately documented per 2 C.F.R. § 200.403(g).
Examples of the types of documents that would cover this information include but are not limited to:
• Solicitation documentation, such as requests for quotes, invitations for bids, or requests for
proposals;
• Responses to solicitations, such as quotes, bids, or proposals;
• Pre-solicitation independent cost estimates and post-solicitation cost/price analyses on file for
review by federal personnel, if applicable;
• Contract documents and amendments, including required contract provisions; and
• Other documents required by federal regulations applicable at the time a grant is awarded to a
recipient.
Additional information on required procurement records can be found on pages 24-26 of the PDAT
Field Manual.
Preparedness Grants Manual | May 2022 43
Records Retention
Record Retention Period
Financial records, supporting documents, statistical records, and all other non-federal entity records
pertinent to a federal award generally must be maintained for at least three years from the date the final
FFR is submitted. See 2 C.F.R. § 200.334. Further, if the recipient does not submit a final FFR and the
award is administratively closed, FEMA uses the date of administrative closeout as the start of the general
record retention period.
The record retention period may be longer than three years or have a different start date in certain
cases. These include:
• Records for real property and equipment acquired with federal funds must be retained for three
years after final disposition of the property. See 2 C.F.R. § 200.334(c).
• If any litigation, claim, or audit is started before the expiration of the three-year period, the
records must be retained until all litigation, claims, or audit findings involving the records have
been resolved and final action taken. See 2 C.F.R. § 200.334(a).
• The record retention period will be extended if the recipient is notified in writing of the
extension by FEMA, the cognizant or oversight agency for audit, or the cognizant agency for
indirect costs. See 2 C.F.R. § 200.334(b).
• Where FEMA requires recipients to report program income after the period of performance ends,
the program income record retention period begins at the end of the recipient’s fiscal year
in which program income is earned. See 2 C.F.R. § 200.334(e).
• For indirect cost rate proposals, cost allocation plans, or other rate computations records, the start
of the record retention period depends on whether the indirect cost rate documents were
submitted for negotiation. If the indirect cost rate documents were submitted for negotiation,
the record retention period begins from the date those documents were submitted for
negotiation. If indirect cost rate documents were not submitted for negotiation, the record
retention period begins at the end of the recipient’s fiscal year or other accounting period
covered by that indirect cost rate. See 2 C.F.R. § 200.334(f).
Types of Records to Retain
FEMA requires that non-federal entities maintain the following documentation for federally funded
purchases:
• Specifications;
• Solicitations;
• Competitive quotes or proposals;
• Basis for selection decisions;
• Purchase orders;
• Contracts;
• Invoices; and
• Canceled checks.
Non-federal entities should keep detailed records of all transactions involving the grant. FEMA may at
any time request copies of any relevant documentation and records, including purchasing documentation
along with copies of canceled checks for verification. See, e.g., 2 C.F.R. §§ 200.318(i), 200.334, 200.337.
Preparedness Grants Manual | May 2022 44
In order for any cost to be allowable, it must be adequately documented per 2 C.F.R. § 200.403(g). Non-
federal entities who fail to fully document all purchases may find their expenditures questioned and
subsequently disallowed.
Actions to Address Noncompliance
Non-federal entities receiving financial assistance from FEMA are required to comply with requirements
in the terms and conditions of their awards or subawards, including the terms set forth in applicable
federal statutes, regulations, NOFOs, policies, and this Manual. Throughout the award lifecycle or even
after an award has been closed, FEMA or the pass-through entity may discover potential or actual
noncompliance on the part of a recipient or subrecipient. This potential or actual noncompliance may be
discovered through routine monitoring, audits, closeout, or reporting from various sources.
In the case of any potential or actual noncompliance, FEMA may place special conditions on an award
per 2 C.F.R. §§ 200.208 and 200.339, FEMA may place a hold on funds until the matter is corrected, or
additional information is provided per 2 C.F.R. § 200.339, or it may do both. Similar remedies for
noncompliance with certain federal civil rights laws are authorized pursuant to 44 C.F.R Parts 7 and 19.
In the event the noncompliance is not able to be corrected by imposing additional conditions or the
recipient or subrecipient refuses to correct the matter, FEMA might take other remedies allowed under 2
C.F.R. § 200.339. These remedies include actions to disallow costs, recover funds, wholly or partly
suspend or terminate the award, initiate suspension and debarment proceedings, withhold further federal
awards, or take other remedies that may be legally available. For further information on termination due
to noncompliance, see the section on Termination Provisions in the relevant NOFO.
FEMA may discover and take action on noncompliance even after an award has been closed. The
closeout of an award does not affect FEMA’s right to disallow costs and recover funds as long as the
action to disallow costs takes place during the record retention period. See 2 C.F.R. §§ 200.334,
200.345(a). Closeout also does not affect the obligation of the non-federal entity to return any funds due
as a result of later refunds, corrections, or other transactions. See 2 C.F.R. § 200.345(a)(2).
The types of funds FEMA might attempt to recover include, but are not limited to, improper payments,
cost share reimbursements, program income, interest earned on advance payments, or equipment
disposition amounts.
FEMA may seek to recover disallowed costs through a Notice of Potential Debt Letter, a Remedy
Notification, or other letter. The document will describe the potential amount owed, the reason why
FEMA is recovering the funds, the recipient’s appeal rights, the requirement to retain records, how the
amount can be paid, and the consequences, including billing and collection, for not appealing or paying
the amount by the deadline.
If the recipient neither appeals nor pays the amount by the deadline, the amount owed will become final.
Potential consequences if the debt is not paid in full or otherwise resolved by the deadline include the
assessment of interest, administrative fees, and penalty charges; administratively offsetting the debt
against other payable federal funds; and transferring the debt to the U.S. Department of the Treasury for
collection.
FEMA notes the following common areas of noncompliance for the preparedness grant programs:
• Insufficient documentation and lack of record retention;
Preparedness Grants Manual | May 2022 45
• Failure to follow the procurement under grants requirements;
• Failure to submit closeout documents in a timely manner;
• Failure to follow EHP requirements; and
• Failure to comply with the POP deadline.
Audits
FEMA grant recipients are subject to audit oversight from multiple entities including the DHS OIG, the
GAO, the pass-through entity, or independent auditing firms for single audits, and may cover activities
and costs incurred under the award. Auditing agencies such as the DHS OIG, the GAO, and the pass-
through entity (if applicable), and FEMA in its oversight capacity, must have access to records pertaining
to the FEMA award. Recipients and subrecipients must retain award documents for at least three years
from the date the final FFR is submitted, and even longer in many cases subject to the requirements of 2
C.F.R. § 200.334. In the case of administrative closeout, documents must be retained for at least three
years from the date of closeout, or longer subject to the requirements of 2 C.F.R. § 200.334. If documents
are retained longer than the required retention period, the DHS OIG, the GAO, and the pass-through
entity, as well as FEMA in its oversight capacity, have the right to access these records as well. See 2
C.F.R. §§ 200.334, 200.337.
Additionally, non-federal entities must comply with the single audit requirements at 2 C.F.R. Part 200,
Subpart F. Specifically, non-federal entities, other than for-profit subrecipients, that expend $750,000 or
more in federal awards during their fiscal year must have a single or program-specific audit conducted for
that year in accordance with Subpart F. 2 C.F.R. § 200.501. A single audit covers all federal funds
expended during a fiscal year, not just FEMA funds. The cost of audit services may be allowable per 2
C.F.R. § 200.425, but non-federal entities must select auditors in accordance with 2 C.F.R. § 200.509,
including following the proper procurement procedures. For additional information on single audit
reporting requirements, see the section in this Manual titled “Single Audit Report.”
The objectives of single audits are to:
• Determine if financial statements conform to generally accepted accounting principles (GAAP);
• Determine whether the schedule of expenditures of federal awards is presented fairly;
• Understand, assess, and test the adequacy of internal controls for compliance with major
programs; and
• Determine if the entity complied with applicable laws, regulations, and contracts or grants.
For single audits, the auditee is required to prepare financial statements reflecting its financial position, a
schedule of federal award expenditures, and a summary of the status of prior audit findings and
questioned costs. The auditee also is required to follow up and take appropriate corrective actions on new
and previously issued but not yet addressed audit findings. The auditee must prepare a corrective action
plan to address the new audit findings. See 2 C.F.R. §§ 200.508, 200.510, 200.511.
Non-federal entities must have an audit conducted, either single or program-specific, of their financial
statements and federal expenditures annually or biennially pursuant to 2 C.F.R. § 200.504. Non-federal
entities must also follow the information submission requirements of 2 C.F.R. § 200.512, including
submitting the audit information to the Federal Audit Clearinghouse within the earlier of 30 calendar days
after receipt of the auditor’s report(s) or nine months after the end of the audit period. The audit
information to be submitted include the data collection form described at 2 C.F.R. § 200.512(c) and
Appendix X to 2 C.F.R. Part 200 as well as the reporting package described at 2 C.F.R. § 200.512(b).
Preparedness Grants Manual | May 2022 46
The non-federal entity must retain one copy of the data collection form and one copy of the reporting
package for three years from the date of submission to the Federal Audit Clearinghouse. 2 C.F.R. §
200.512; see also 2 C.F.R. § 200.517 (setting requirements for retention of documents by the auditor and
access to audit records in the auditor’s possession).
FEMA, the DHS OIG, the GAO, and the pass-through entity (if applicable), as part of monitoring or as
part of an audit, may review a non-federal entity’s compliance with the single audit requirements. In cases
of continued inability or unwillingness to have an audit conducted in compliance with 2 C.F.R. Part 200,
Subpart F, FEMA and the pass-through entity, if applicable, are required to take appropriate remedial
action under 2 C.F.R. § 200.339 for noncompliance, pursuant to 2 C.F.R. § 200.505.
Payment Information
FEMA uses the Direct Deposit/Electronic Funds Transfer (DD/EFT) method of payment to recipients. To
enroll in the DD/EFT, the recipient must complete the SF-1199A, Direct Deposit Form.
FEMA utilizes the Payment and Reporting System (PARS) for financial reporting, invoicing and tracking
payments. For additional information, refer to
https://isource.fema.gov/sf269/execute/LogIn?sawContentMessage=true.
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National Campaigns and Programs
Preparedness grant funding can generally be used to support the following campaigns and programs that
have been developed by or in partnership with DHS or FEMA.
FEMA Strategic Plan
The 2022-2026 FEMA Strategic Plan outlines a bold vision and three ambitious goals designed to address
key challenges the agency faces during a pivotal moment in the field of emergency management. Wide-
ranging and long-term, the goals defined in the plan respond to the changing landscape in which we find
ourselves. The goals to meet this challenge are:
• Goal 1 - Instill Equity as a Foundation of Emergency Management: disasters impact people
and communities differently. Every disaster occurs within a unique context based on a
community’s geographic, demographic, political, historical, and cultural characteristics. These
unique contexts require tailored solutions that are designed to meet their unique needs;
• Goal 2 - Lead Whole of Community in Climate Resilience: climate change represents a
profound crisis for the nation, making natural disasters more frequent, more intense, and more
destructive. The growing severity of disasters increases the time it takes for communities to
recover – a process that can be further complicated by repeat events in areas already struggling to
bounce back. These cascading and compounding impacts, propelled by climate change, pose the
greatest risk to our communal and nationwide resilience; and
• Goal 3 - Promote and Sustain a Ready FEMA and Prepared Nation: the increase in
frequency, severity, and complexity of emergency, disaster, and fire incidents has heightened
demands on FEMA and on the larger emergency management community. FEMA must expand
its approach to agency readiness and to national preparedness. The only way to achieve this is to
increase the nation’s overall emergency management capabilities at all levels of government, as
well as the private sector, the nonprofit sector, and among individuals.
These goals position FEMA to address the increasing range and complexity of disasters, support the
diversity of communities we serve, and complement the nation’s growing expectations of the emergency
management community. All preparedness grant program recipients are encouraged to review the 2022-
2026 FEMA Strategic Plan and consider how FY 2022 grant funding can be used to support the Plan’s
goals and objectives of equity, climate resilience, and readiness as they apply to an entity’s specific needs
and the needs of the whole community. We invite all stakeholders and partners to also adopt these
priorities and join us in building a more prepared and resilient nation.
Whole Community Preparedness
Preparedness is a shared responsibility that calls for the involvement of everyone—not just the
government—in preparedness efforts. By working together, everyone can help keep the nation safe from
harm and help keep it resilient when struck by hazards, such as natural disasters, acts of terrorism, and
pandemics.
Whole Community includes:
• Individuals and families, including those with access and functional needs;
• Businesses;
Preparedness Grants Manual | May 2022 48
• Faith-based and community organizations;
• Nonprofit groups;
• Schools and academia;
• Media outlets; and
• All levels of government, including state, local, tribal, territorial, and federal partners.
The phrase “Whole Community” often appears repeatedly in preparedness materials, as it is one of the
guiding principles. It means two things:
1. Involving people in the development of national preparedness documents; and
2. Ensuring their roles and responsibilities are reflected in the content of the materials.
Additional information on incorporating whole community preparedness is available in the relevant
program-specific appendix to this Manual, as applicable.
Active Shooter Preparedness
DHS aims to enhance national preparedness through a whole-community approach by providing the
necessary products, tools, and resources to help all stakeholders prepare for and respond to an active
shooter incident. To that end, DHS has developed a comprehensive Active Shooter Preparedness website,
which includes informational resources, available at https://www.cisa.gov/active-shooter-preparedness.
An additional resource, the Joint DHS and Federal Bureau of Investigation (FBI) Countering Violent
Extremism (CVE) and Active Shooter Web Portal is located within the Homeland Security Information
Network (HSIN). The portal provides a restricted-access forum to share Unclassified, For Official Use
Only (FOUO), Sensitive but Unclassified (SBU), and Law Enforcement Sensitive (LES) information. The
portal provides users and training practitioners with accurate, appropriate, and relevant CVE and Active
Shooter training development resources, subject-matter expert information, and outreach initiatives. It
also has forums to provide feedback, products useful to others, and allows participants to ask questions
concerning CVE or the Active Shooter Program. Persons with a job-related duty, public service interest,
or who support a CVE and/or Active Shooter program can request access to this Portal. Additional
information can be found at: https://www.dhs.gov/cveas-portal#.
States and high-risk urban areas are encouraged to review the referenced active shooter guidance,
evaluate their preparedness needs, and consider applying for funding to address any needs identified in
this area (please see the most current NOFO for allowable costs). To address training needs associated
with active shooter incidents, FEMA’s Emergency Management Institute provides a free, web-based
training course entitled IS-907: Active Shooter: What You Can Do, available at the following website:
https://training.fema.gov/is/courseoverview.aspx?code=is-907.
Soft Targets and Crowded Places
There are continued and growing threats facing Soft Targets and Crowded Places (ST-CP) throughout the
nation. ST-CPs are those locations or environments that are easily accessible to large numbers of people
on a predictable or semi-predictable basis that have limited security or protective measures in place.
These locations are vulnerable to attack using simple tactics and readily accessible weapons such as small
arms, edged weapons, vehicles, improvised explosive devices, and unmanned aircraft systems. ST-CPs
can include places such as town centers, shopping malls, open-air venues, outside hard targets/venues
perimeters, and other places of meeting and gathering. DHS is committed to reducing the risk of attacks
against ST-CPs and the impact of attacks if they do occur. However, the protection and security of ST-
Preparedness Grants Manual | May 2022 49
CPs is a shared responsibility among whole community partners including the public, ST-CP owners and
operators, security industry partners, the Federal Government, and SLTT government partners. States,
territories, high-risk urban areas, and public and private sector partners are encouraged to identify security
gaps and build capabilities that address security needs of ST-CPs, understanding the unique challenges
related to protecting locations that are open to the public. States, territories, high-risk urban areas, and
public and private sector partners are also encouraged to use resources to instill a culture of awareness,
vigilance, and preparedness. For more information and additional resources, please see the DHS’s
Hometown Security Program.
Community Lifelines
FEMA created Community Lifelines to reframe incident information, understand and communicate
incident impacts using plain language, and promote unity of effort across the whole community to
prioritize efforts to stabilize the lifelines during incident response. Although lifelines were developed to
support response planning and operations, the concept can be applied across the entire preparedness cycle.
Efforts to protect lifelines, prevent and mitigate potential impacts to them, and build back stronger and
smarter during recovery will drive overall resilience of the nation. Applying the lifelines construct allows
decision-makers to:
• Prioritize, sequence, and focus response efforts towards maintaining or restoring the most critical
services and infrastructure;
• Utilize a common lexicon to facilitate unity of purpose among all stakeholders;
• Promote a response that facilitates unity of purpose and better communication among the whole
community (federal, state, tribal, territorial, and local governments, and private sector and non-
governmental entities); and
• Clarify which components of the disaster are complex (multifaceted) or complicated (difficult),
requiring cross-sector coordination.
Lifelines are used to:
• Enhance the ability to gain, maintain, and communicate situational awareness for the whole
community in responding to disasters;
• Analyze impacts to the various lifelines and develop priority focus areas for each operational
period during response;
• Identify and communicate complex interdependencies to identify major limiting factors hindering
stabilization; and
• Update the National Response Framework to reflect use of lifelines in response planning.
Lifelines include opportunities to:
• Enable a true unity of effort between government, non-governmental organizations, and the
private sector, including infrastructure owners and operators;
• Integrate preparedness efforts, existing plans, and identify unmet needs to better anticipate
response requirements; and
• Refine reporting sources and products to enhance situational awareness, best determine capability
gaps, and demonstrate progress towards stabilization.
For more information on lifelines, please visit FEMA’s Community Lifelines Page and Implementation
Toolkit.
Preparedness Grants Manual | May 2022 50
Strategic Framework for Countering Terrorism and Targeted Violence
The United States faces increasingly complex threats from terrorism and targeted violence. Both continue
to pose a grave threat in ways that have evolved dramatically in the nearly two decades since the 9/11
attacks. Although foreign terrorist organizations remain intent on striking our Homeland, we also face a
growing threat from domestic actors. Combating terrorism and targeted violence requires the combined
efforts of DHS, our federal and SLTT government partners, and civil society.
To address these threats, in September 2019 DHS adopted the DHS Strategic Framework for Countering
Terrorism and Targeted Violence which explains how the department will use the tools and expertise that
have protected and strengthened the country from foreign terrorist organizations to address the evolving
challenges of today. DHS has also now finalized a corresponding Public Action Plan. Preparedness grant
recipients are encouraged to familiarize themselves with these documents and consider adopting the
concepts, principals, and goals they outline.
Countering Violent Extremism (CVE) Training
Per FEMA Grant Programs Directorate Information Bulletin 432, Review and Approval Requirements for
Training Courses Funded Through Preparedness Grants, issued on July 19, 2018, states, territories, tribal
entities, and high-risk urban areas are no longer required to request approval from FEMA for personnel to
attend non-DHS FEMA training as long as the training is coordinated with and approved by the state,
territory, tribal, or high-risk urban area Training Point of Contact (TPOC) and falls within the FEMA
mission scope and the jurisdiction’s Emergency Operations Plan.
FEMA will conduct periodic reviews of all state, territory, and high-risk urban area training funded by
FEMA. These reviews may include requests for all course materials and physical observation of, or
participation in, the funded training. If these reviews determine that courses are outside the scope of this
guidance, the costs will be disallowed.
For further information on developing courses using the instructional design methodology and tools that
can facilitate the process, State Administrative Agencies, and TPOCs are encouraged to review the
National Training and Education Division Training Resource and Development Center website at First
Responder Training Resource and Development Center.
All training, presentations, and speakers regarding CVE must be consistent with DHS and U.S.
Government policy, in particular by avoiding the use of hostile, stereotypical, or factually inaccurate
information about Muslims and Islam or any community, and by emphasizing the importance of
community engagement and interaction to promote communities as part of the solution rather than the
problem needing solution.
Foreign terrorist groups and individual terrorist thought leaders are seeking to recruit or inspire
Westerners to carry out attacks against western and U.S. targets. They seek to recruit and/or inspire
individuals living in communities with the U.S. via, but not limited to, print, video, and social media, as
well as through personal interaction. But we also know that violent extremism is not a phenomenon
restricted solely to one community and that any effort to counter violent extremism must be applicable to
all ideologically motivated violence. Efforts to provide information and training regarding CVE should
emphasize the strength of local communities approach. The following are examples that demonstrate the
integration of community engagement and CVE that reflect the strength of local communities approach:
Preparedness Grants Manual | May 2022 51
• Training objectives should be clearly defined to meet specific CVE goals, such as community
engagement, cultural awareness, community-based policing, etc.;
• Engaging diverse American communities around CVE may require working with local grassroots
community organizations to develop engagement and outreach initiatives;
• Training programs should be sensitive to Constitutional values, such as protecting fundamental
civil rights and civil liberties, and eschew notions of racial and ethnic profiling;
• It may be necessary to conduct vetting procedures for self-selected CVE training experts who
offer programs that may claim to address CVE, but serve to demonize certain individuals or
whole cross sections of a community;
• Training programs must ensure that the clearly defined objectives are in line with DHS strategies
to counter violent extremism;
• It may be necessary to provide a review process to determine if CVE training focuses on
community engagement and outreach;
• Support may be needed for law enforcement to increase knowledge, skills, and abilities to
increase engagement techniques with diverse American communities; and
• Cultural awareness courses of diverse American communities may be necessary to ensure
stakeholders are taught to work with communities and build trust, rather than feed existing
misconceptions and stereotypes of people, culture, or religion.
HSGP Appendix | May 2022 Page A-1
Program Appendix A:
Homeland Security Grant Program (HSGP)
As a reminder, while this appendix contains HSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the HSGP. Please be sure to read the main content of this Manual
in addition to the program-specific appendices.
Alignment of HSGP to the National Preparedness System
The Nation uses the National Preparedness System to build, sustain, and deliver core capabilities to
achieve the National Preparedness Goal (the Goal). Recipients will use the National Preparedness System
to support their efforts to build, sustain, and deliver these core capabilities. The components of the National
Preparedness System are Identifying and Assessing Risk, Estimating Capability Requirements, Building
and Sustaining Capabilities, Planning to Deliver Capabilities, Validating Capabilities, and Reviewing and
Updating. Additional information on the National Preparedness System is available at
http://www.fema.gov/national-preparedness-system.
As the National Preparedness System matures, we are getting better data on our capabilities as a Nation
that can be used to drive our focus and our resources at all levels. States and territories provide annual
data on their proficiency across 32 core capabilities through the Threat and Hazard Identification and Risk
Assessment (THIRA), Stakeholder Preparedness Review (SPR), exercise and real world after-action
reports, and other preparedness data. This data feeds into the National Preparedness Report and forms a
shared national picture of needs relative to capability gaps—including what threats and hazards are posing
the greatest risks, and what core capabilities are most in need of improvement or sustainment.
Communities and federal agencies alike use this data to prioritize, synchronize, and guide programs and
activities to build and sustain capabilities. Analytic results help shape prioritization decisions at FEMA
and across the nation to make sure we are focusing our time and our resources in the right areas.
The HSGP provides financial support to state, local, tribal, and territorial (SLTT) jurisdictions to help
them build, sustain, and deliver core capabilities identified in the Goal. A key focus and requirement of
the HSGP is to prevent terrorism and other catastrophic events and to prepare the Nation for the threats
and hazards that pose the greatest risk to the security of the United States, including risks along the
Nation’s borders. When applicable, funding should support deployable assets that can be used anywhere
in the Nation through automatic assistance and mutual aid agreements, including, but not limited to, the
Emergency Management Assistance Compact (EMAC).
The HSGP supports investments that improve the ability of jurisdictions nationwide to:
• Prevent a threatened or an actual act of terrorism;
• Protect citizens, residents, visitors, and assets against the threats that pose the greatest risk to the
security of the United States;
• Mitigate the loss of life and property by lessening the impact of future catastrophic events;
• Respond quickly to save lives, protect property and the environment, and meet basic human
needs in the aftermath of a catastrophic incident; and/or
• Recover through a focus on the timely restoration, strengthening, accessibility, and revitalization
of infrastructure, housing, and a sustainable economy, as well as the health, social, cultural,
HSGP Appendix | May 2022 Page A-2
historic, and environmental fabric of communities affected by a catastrophic incident, and do so
in a manner that engages the whole community while ensuring the protection of civil rights.
HSGP Funding Guidelines
Recipients must comply with all the requirements in 2 C.F.R. Part 200 (Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards). In general, recipients should
consult with their FEMA HQ Preparedness Officer prior to making any investment that does not clearly
meet the allowable expense criteria. Funding guidelines established within this section support the five
mission areas—Prevention, Protection, Mitigation, Response, and Recovery—and associated core
capabilities within the Goal. Allowable investments made in support of the national priorities, as well as
other capability-enhancing projects must have a nexus to terrorism preparedness and fall into the
categories of planning, organization, exercises, training, or equipment, aligned to closing capability gaps
or sustaining capabilities identified in the THIRA/SPR. Recipients are encouraged to use grant funds for
evaluating grant-funded project effectiveness and return on investment. FEMA encourages recipients to
provide the results of that analysis to FEMA.
Multiple Purpose or Dual-Use of Funds
For both the State Homeland Security Program (SHSP) and Urban Area Security Initiative (UASI), many
activities that support the achievement of core capabilities related to the national priorities and terrorism
preparedness may simultaneously support enhanced preparedness for other hazards unrelated to acts of
terrorism. However, all SHSP- and UASI-funded projects must assist recipients and subrecipients in
achieving core capabilities related to preventing, preparing for, protecting against, or responding to acts of
terrorism per section 2008(c) of the Homeland Security Act of 2002 (6 U.S.C. § 609(c)).
Planning (SHSP and UASI)
SHSP and UASI funds may be used for a range of emergency preparedness and management planning
activities, such as those associated with the development, review, and revision of the THIRA, SPR,
continuity plans, and other planning activities that support the Goal and placing an emphasis on updating
and maintaining a current Emergency Operations Plan (EOP) that conforms to the guidelines outlined in
Comprehensive Preparedness Guide (CPG) 101 v2. Planning efforts can also include conducting risk and
resilience assessments on increasingly connected cyber and physical systems, on which security depends,
using the Infrastructure Resilience Planning Framework and related Cybersecurity and Infrastructure
Security Agency (CISA) resources.
Additionally, SHSP and UASI funds may be used for planning efforts related to state court cybersecurity,
911 call capabilities, alert and warning capabilities, and implementation of the REAL ID Act (Pub. L. No.
109-13).
Organization (SHSP and UASI)
States and high-risk urban areas must justify proposed expenditures of SHSP or UASI funds to support
organization activities within their Investment Justification (IJ) submission. Organizational activities
include:
• Program management;
• Development of whole community partnerships, through groups such as Citizen Corp Councils;
• Structures and mechanisms for information sharing between the public and private sector;
• Implementing models, programs, and workforce enhancement initiatives to address
ideologically inspired radicalization to violence in the homeland;
HSGP Appendix | May 2022 Page A-3
• Tools, resources, and activities that facilitate shared situational awareness between the public
and private sectors;
• Operational Support;
• Utilization of standardized resource management concepts such as typing, inventorying,
organizing, and tracking to facilitate the dispatch, deployment, and recovery of resources before,
during, and after an incident;
• Responding to an increase in the threat level under the National Terrorism Advisory System
(NTAS) or needs resulting from a National Special Security Event;
• Paying salaries and benefits for personnel to serve as qualified Intelligence Analysts. Per the
Personnel Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security
Act (PRICE Act), Pub. L. No. 110-412, § 2, codified in relevant part, as amended, at 6 U.S.C. §
609(a), SHSP and UASI funds may be used to hire new staff and/or contractor positions to serve
as intelligence analysts to enable information/intelligence sharing capabilities, as well as support
existing intelligence analysts previously covered by SHSP or UASI funding. See 6 U.S.C. §
609(a). To be hired as an intelligence analyst, staff and/or contractor personnel must meet at least
one of the following criteria:
o Complete training to ensure baseline proficiency in intelligence analysis and production
within six months of being hired; and/or, o Previously served as an intelligence analyst for a minimum of two years either in a
federal intelligence agency, the military, or state and/or local law enforcement
intelligence unit.
• All fusion center analytical personnel must demonstrate qualifications that meet or exceed
competencies identified in the Common Competencies for state, local, and tribal intelligence
analysts, which outlines the minimum categories of training needed for intelligence analysts. A
certificate of completion of such training must be on file with the State Administrative Agency
(SAA) and must be made available to the recipient’s respective FEMA HQ Preparedness Officer
upon request; and
• Migrating online services to the “.gov” internet domain.
All SAAs are allowed to use up to 50% of their SHSP funding, and all high-risk urban areas are allowed to
use up to 50% of their UASI funding, for personnel costs per 6 U.S.C. § 609(b)(2)(A). Personnel hiring,
overtime, and backfill expenses are permitted under this grant only to the extent that such expenses are for
the allowable activities within the scope of the grant. Personnel expenses may include, but are not limited
to training and exercise coordinators, program managers and planners, intelligence analysts, and
Statewide Interoperability Coordinators (SWICs).
At the request of a recipient, the FEMA Administrator (or their designee) may grant a waiver of this 50%
limitation under 6 U.S.C. § 609(b)(2)(B). Requests for waivers to the personnel cap must be submitted by
the authorized representative of the SAA to FEMA in writing on official letterhead, with the following
information:
• Documentation explaining why the cap should be waived;
• Conditions under which the request is being submitted; and
• A budget and method of calculation of personnel costs both in percentages of the grant award
and in total dollar amount.
Please see Information Bulletin (IB) 421b, Clarification on the Personnel Reimbursement for Intelligence
Cooperation and Enhancement of Homeland Security Act of 2008 (Public L. No. 110–412 – the PRICE
Act), dated October 30, 2019, for additional information on the waiver request process.
HSGP Appendix | May 2022 Page A-4
Organizational activities under SHSP and UASI include:
Operational Overtime Costs. In support of efforts to enhance capabilities for detecting, deterring,
disrupting, and preventing acts of terrorism and other catastrophic events, operational overtime costs are
allowable for increased protective security measures at critical infrastructure sites or other high-risk
locations and to enhance public safety during mass gatherings and high-profile events. In that regard, HSGP
recipients are urged to consider using grant funding to support soft target preparedness activities. SHSP or
UASI funds may be used to support select operational expenses associated with increased security measures
in the authorized categories cited in the table below, but this table is not exhaustive. FEMA retains the
discretion to approve other types of requests that do not fit within one of the categories of the table.
Table 2 - Authorized Operational Overtime Categories
Category Description
1
National Terrorism
Advisory System
(NTAS)
Security measures in response to an increase in the threat level
under the NTAS to an “elevated” or “imminent” alert status. FEMA
Information Bulletin No. 367, Impact of National Terrorism
Advisory System on Homeland Security Grant Programs, remains
applicable; therefore, advance authorization from FEMA is not
required. Refer to https://www.dhs.gov/topic/ntas for additional
information on the NTAS.
2 National Security
Special Event (NSSE)
Security measures for a designated NSSE. NSSEs are events of
national or international significance deemed by DHS to be a
potential target for terrorism or other criminal activity.
3
Special Event
Assessment Rating
(SEAR) Level 1 through
Level 4 Events
Security measures required for SEAR Level 1 through Level 4
events as designated by DHS and included in the DHS National
Special Events List, as defined below:
• SEAR 1: A significant event with national and/or
international importance that may require extensive federal
interagency support.
• SEAR 2: A significant event with national and/or
international importance that may require some level of
federal interagency support.
• SEAR 3: An event of national and/or international
importance that requires only limited federal support.
• SEAR 4: An event with limited national importance that is
managed at state and local level.
NOTE: In cases where a threat of terrorism can be associated with a
SEAR Level 5 event, the event planners should coordinate with their
state or territory Homeland Security Advisor to seek re-adjudication
of the SEAR rating. Operational overtime for security measures
associated with such events will be considered for approval by
FEMA if re-adjudication results in a SEAR 1 through 4 rating.
4 States of Emergency
Declarations of states of emergency by the Governor associated with
a terrorism-related threat or incident. This excludes Presidentially
declared major disasters or emergencies where federal funding
support for the proposed grant-funded activity is made available
through the FEMA Public Assistance program or other federal
disaster grants.
HSGP Appendix | May 2022 Page A-5
Category Description
5
National Critical
Infrastructure
Prioritization Program
(NCIPP)
Protection of Level 1 and Level 2 facilities identified through DHS’s
NCIPP based on a terrorism-related threat to critical infrastructure.
6 Directed Transit Patrols Targeted security patrols in airports and major transit hubs based on
a terrorism-related threat to transportation systems.
7 Other Related Personnel
Overtime Costs
Overtime costs may be authorized for personnel assigned to directly
support any of the security activities relating to the categories above.
Examples include firefighters and emergency medical services
personnel; public works employees who may be responsible for
installing protective barriers and fencing; public safety personnel
assigned to assist with event access and crowd control; emergency
communications specialists; backfill and overtime for staffing state
or major urban area fusion centers; state Active Duty National
Guard deployments to protect critical infrastructure sites, including
all resources that are part of the standard National Guard
deployment package (note: consumable costs, such as fuel expenses,
are not allowed except as part of the standard National Guard
deployment package); contract security services for critical
infrastructure sites; participation in Regional Resiliency Assessment
Program activities, increased border security activities in
coordination with USBP, etc.
8 Operational Support to
a Federal Agency
Overtime costs are allowable for personnel to participate in
information, investigative, and intelligence sharing activities related
to homeland security/terrorism preparedness and specifically
requested by a federal agency. Allowable costs are limited to
overtime associated with federally requested participation in eligible
activities, including anti-terrorism task forces, Joint Terrorism Task
Forces (JTTFs), Area Maritime Security Committees (as required by
the Maritime Transportation Security Act of 2002), DHS Border
Enforcement Security Task Forces, and Integrated Border
Enforcement Teams. In addition, reimbursement for operational
overtime law enforcement activities related to combating
transnational crime organizations in support of efforts to enhance
capabilities for detecting, deterring, disrupting, and preventing acts
of terrorism is an allowable expense under SHSP and UASI on a
case-by-case basis. Grant funding can only be used in proportion to
the federal man-hour estimate and only after funding for these
activities from other federal sources (i.e., FBI JTTF payments to
state and local agencies) has been exhausted.
All allowable operational overtime costs are also subject to the administration requirements outlined in
the following subsection.
Administration of Operational Overtime Requests
• Except for an elevated NTAS alert, SHSP or UASI funds may only be spent for operational
overtime costs upon prior written approval by FEMA. The SAA must submit operational
overtime requests in writing to its assigned FEMA Preparedness Officer. FEMA will consider
HSGP Appendix | May 2022 Page A-6
requests for special event activities up to one year in advance. However such requests must be
within the award’s current POP and must not result in the need for a request to extend the period
of performance. SAAs should contact the Centralized Scheduling and Information Desk (CSID)
for Preparedness Officer contact information. CSID can be reached by phone at (800) 368-6498
or by e-mail at askcsid@fema.dhs.gov, Monday through Friday, 9a.m. – 5p.m. ET;
• All operational overtime requests must clearly explain how the request meets the criteria of one
or more of the categories listed in the table above. Requests must address the threat environment
as it relates to the event or activity requiring operational overtime support and explain how the
overtime activity is responsive to the threat. Request letters sent to FEMA must be
UNCLASSIFIED but may be labeled “For Official Use Only.” If explaining the threat will
require the sharing of classified information, the letter should state that fact. FEMA will then plan
for the sharing of classified information through official channels;
• Post-event operational overtime requests will only be considered on a case-by-case basis, where it
is demonstrated that exigent circumstances prevented submission of a request in advance of the
event or activity;
• Under no circumstances may FEMA grant funding be used to pay for costs already supported by
funding from another federal source;
• States with UASI jurisdictions can use funds retained at the state level to reimburse eligible
operational overtime expenses incurred by the state (per the above guidance limitations). Any
UASI funds retained by the state must be used in direct support of the high-risk urban area. States
must provide documentation to the Urban Area Working Group (UAWG) and FEMA upon
request demonstrating how any UASI funds retained by a state would directly support the high-
risk urban area; and
• FEMA will consult and coordinate with appropriate DHS components as necessary to verify
information used to support operational overtime requests.
Personnel Costs. Personnel hiring, overtime, and backfill expenses are permitted under this grant to
perform allowable HSGP planning, training, exercise, and equipment activities. Personnel may include
but are not limited to training and exercise coordinators, program managers for activities directly
associated with SHSP and UASI funded activities, intelligence analysts, and SWICs.
For further details, SAAs should refer to IB #421b, or contact their FEMA Preparedness Officer. HSGP
funds may not be used to support the hiring of any personnel to fulfill traditional public health and safety
duties nor to supplant traditional public health and safety positions and responsibilities. The following
definitions apply to personnel costs:
• Hiring. State and local entities may use grant funding to cover the salary of newly hired personnel
who are exclusively undertaking allowable FEMA grant activities as specified in this guidance.
This may not include new personnel who are hired to fulfill any non-FEMA program activities
under any circumstances. Hiring will always result in a net increase of Full Time Equivalent
(FTE) employees.
• Overtime. These expenses are limited to the additional costs that result from personnel working
over and above 40 hours of weekly work time as the direct result of their performance of FEMA-
approved activities specified in this guidance. Overtime associated with any other activity is not
eligible.
• Backfill-Related Overtime. Also called “Overtime as Backfill,” these expenses are limited to
overtime costs that result from personnel who are working overtime (as identified above) to
perform the duties of other personnel who are temporarily assigned to FEMA-approved activities
outside their core responsibilities. Neither overtime nor backfill expenses are the result of an
increase of FTE employees.
HSGP Appendix | May 2022 Page A-7
• Supplanting. Grant funds will be used to supplement existing funds and will not replace
(supplant) funds that have been appropriated for the same purpose. Applicants or recipients may
be required to supply documentation certifying that a reduction in non-federal resources occurred
for reasons other than the receipt or expected receipt of federal funds.
Organization (OPSG)
Personnel Costs
OPSG funds may be used for domestic travel and per diem, including costs associated with the
deployment/redeployment of personnel to border areas and for travel associated with law enforcement
entities assisting other local jurisdictions in law enforcement activities. In addition, allowable costs
include supporting up to six-month deployment of law enforcement personnel to critical Southwest
Border locations for operational activities (travel costs must be in accordance with applicable travel
regulations).
Operational Overtime Costs
OPSG funds should be used for operational overtime costs associated with law enforcement activities in
support of border law enforcement agencies for enhanced border security. Overtime pay is for increased
patrol time for certified public safety officers, along with limited support for other law enforcement direct
support personnel (e.g., Communication Officers/Dispatchers, non-sworn patrol pilots, etc.). Overtime
shall be reimbursed consistent with the non-federal entity’s overtime policy and the requirements as stated
below:
• Overtime is time worked that exceeds the required number of hours during an employee’s
designated shift;
• Overtime must be worked to increase patrol capacity and be in support of identified and approved
United States Border Patrol (USBP) border security operations;
• The OPSG overtime hourly rate of pay will be no more than the approved overtime rate per local
law and policy and must be in accordance with applicable state and federal regulations;
• All overtime expenses under OPSG must be reasonable for the services rendered and conform to
the non-federal entity’s established written policy, which must apply to both federally funded and
non-federally funded activities and comply with the other applicable requirements under 2 C.F.R.
§§ 200.430-200.431; and
• The non-federal entity may not utilize OPSG funding to pay for an employee’s overtime hours or
pay that exceeds 16 hours worked in any 24-hour period.
Personnel Costs
Up to 50% of an OPSG award may be used to pay for all personnel costs (only to the extent that such
expenses are for the allowable activities within the scope of the grant). At the request of a recipient or
subrecipient, the FEMA Administrator (or designee) may waive the 50% personnel cap. Waiver decisions
are at the discretion of the FEMA Administrator and will be considered on a case-by-case basis in
accordance with IB 421b. 6 U.S.C. § 609(b)(2). A formal OPSG personnel waiver request should:
• Be on official letterhead, include a written justification, and be signed by the local jurisdiction;
• Include a budget and method of calculation of personnel costs both in the percentage of the grant
award and in total dollar amount, reflecting the change in scope or objective to the project;
• Include an approved Operations Order from the USBP Sector office that supports the local
jurisdiction’s written justification; and
• Be coordinated with the USBP Sector, SAA, and the DHS/Customs and Border Protection (CBP)
Office of the Border Patrol (OBP).
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Further, changes in scope or objective also require FEMA’s prior written approval pursuant to 2 C.F.R. §
200.308(c)(1). If the cost changes are allowable under the grant, a Fragmentary Order (FRAGO) must be
submitted to HSIN to obtain FEMA’s prior written approval of such changes in accordance with 2 C.F.R.
§ 200.308(c)(1). These modifications will be annotated in the annex section of the FRAGO.
OPSG funds may be used to pay additional current part-time law enforcement personnel salaries to bring
them to temporary full-time status. OPSG funds may support a Governor’s request to activate, deploy, or
redeploy specialized National Guard Units/Package and/or elements of state law enforcement serving as
friendly forces to increase or augment specialized/technical law enforcement elements’ operational
activities. Costs associated with backfill for personnel supporting operational activities are allowable.
As with all OPSG personnel costs, OPSG grant funds will be used to supplement existing funds and will
not replace (supplant) funds that have been appropriated for the same purpose. Applicants or recipients
may be required to supply documentation certifying that a reduction in non-federal resources occurred for
reasons other than the receipt or expected receipt of federal funds.
Intelligence Support
Per 6 U.S.C. § 609(a), OPSG funds may, as applicable and operationally beneficial, be used to pay
salaries and benefits or overtime for personnel to serve as qualified Intelligence Analysts to enable and
enhance information/intelligence sharing capabilities, as well as support existing intelligence analysts
previously covered by OPSG funding. Qualified OPSG-funded intelligence analysts can be assigned to an
applicable law enforcement facility/intelligence function as long as information/intelligence sharing is
maintained. To serve as an OPSG-funded intelligence analyst, personnel must meet at least one of the
following criteria:
• Complete training to ensure baseline proficiency in intelligence analysis and production within
six months of being hired; and/or,
• Previously served as an intelligence analyst for a minimum of two years either in a federal
intelligence agency, the military, or state and/or local law enforcement intelligence unit.
OPSG-funded intelligence analysts must demonstrate qualifications that meet or exceed competencies
identified in the Common Competencies for state, local, and tribal intelligence analysts, which outlines
the minimum categories of training needed for intelligence analysts. A certificate of completion of such
training must be on file with the SAA and must be made available to the recipient’s respective FEMA HQ
Preparedness Officer upon request.
Temporary or Term Appointments
• Subrecipients may utilize temporary or term appointments to augment the law enforcement
presence on the borders. However, applying funds toward hiring full-time or permanent sworn
public safety officers is unallowable;
• OPSG-funded temporary or term appointments may not exceed the approved period of
performance:
o For OPSG purposes, temporary appointments are non-status appointments for less than
one year; and
o For OPSG purposes, term appointments are non-status appointments for one year,
extendable for one year as necessary.
• OPSG funding for temporary or term appointments may pay for salary only. Benefits are not
allowable expenses for term or temporary employees;
• OPSG remains a non-hiring program. Appropriate uses of temporary or term appointments
include:
HSGP Appendix | May 2022 Page A-9
o To carry out specific enforcement operations work for ongoing OPSG-funded patrols
throughout the Sector Area of Operation;
o To staff operations of limited duration, such as OPSG-enhanced enforcement patrols
targeting specific locations or criminal activity; and
o To fill OPSG positions in activities undergoing transition or personnel shortages and
local backfill policies (medical/military deployments).
• OPSG term and temporary appointments must have all necessary certifications and training to
enforce state and local laws. OPSG funds will not be used to train or certify term or temporary
appointments except as otherwise stated in this Manual and the HSGP Notice of Funding
Opportunity (NOFO); and
• FEMA provides no guarantee of funding for temporary or term appointments. In addition to the
terms of this Manual and the HSGP NOFO, subrecipients must follow their own applicable
policies and procedures regarding temporary or term appointments.
Management and Administration
Management and administration (M&A) costs are allowed. Recipients may use a maximum of up to 5%
of HSGP funds awarded for their M&A, and any funds retained are to be used solely for M&A purposes
associated with the HSGP award. Subrecipients may also retain a maximum of up to 5% of the funding
passed through by the state solely for M&A purposes associated with the HSGP award. M&A activities
are those directly relating to the management and administration of HSGP funds, such as financial
management and monitoring. M&A expenses must be based on actual expenses or known contractual
costs. M&A requests that are simple percentages of the award, without supporting justification, will not
be allowed or considered for reimbursement.
M&A costs are not operational costs. They are the necessary costs incurred in direct support of the grant
or as a consequence of the grant and should be allocated across the entire lifecycle of the grant. Examples
include preparing and submitting required programmatic and financial reports, establishing and/or
maintaining equipment inventory, documenting operational and equipment expenditures for financial
accounting purposes, responding to official informational requests from state and federal oversight
authorities, including completing the Civil Rights Evaluation Tool as required by DHS, and grant
performance measurement or evaluation activities.
Recipients or subrecipients may apply or credit M&A funding toward the recipient’s requirement to
allocate funding toward the National Priority Areas. For example, if a recipient spends $5,000 to manage
or administer its funding dedicated toward its protection of soft targets/crowded places investment, the
recipient may credit that funding toward its requirement to allocate at least 3% of its award to the
protection of soft targets and crowded places National Priority Area.
A state’s HSGP funds for M&A calculation purposes includes the total of its SHSP, UASI, and OPSG
awards. While the SAA may retain up to five percent of this total for M&A, the state must still ensure that
all subrecipient award amounts meet the mandatory minimum pass-through requirements that are
applicable to each HSGP program. To meet this requirement, the percentage of SHSP and UASI funds
passed through to local or tribal jurisdictions must be based on the state’s total HSGP award prior to
withholding any M&A.
In retaining these funds, states may retain a maximum of 2.5% of the OPSG allocation, which must be
withheld from the pass-through to each subrecipient county or tribe in an equal percentage. The SAA may
also retain additional funding from its SHSP award to manage and administer the OPSG award, but that
additional amount is also capped at an amount equal to 2.5% of the OPSG award. Examples applying this
principle:
HSGP Appendix | May 2022 Page A-10
SAA 1:
Total award: $6,000,000
SHSP: $1,000,000 OPSG: $2,500,000 UASI: $2,500,000
M&A Maximum: $300,000 (5 percent of $6,000,000)
Maximum M&A for SHSP = $50,000
Maximum M&A for OPSG = $125,000. Of that amount, $62,500 (2.5 percent) may be retained
from the OPSG allocation, and the other $62,500 would come from the SHSP allocation. Any
amount used to manage and administer OPSG that is charged to SHSP may be above and
beyond the $50,000 available to manage the SHSP allocation.
Maximum M&A for UASI = $125,000
SAA 2:
Total award: $4,500,000
SHSP: $3,500,000 OPSG: $1,000,000
M&A Maximum: $225,000 (5 percent of $4,500,000)
Maximum M&A for SHSP = $175,000
Maximum M&A for OPSG = $50,000. Of that amount, $25,000 (2.5 percent) may be retained
from the OPSG allocation, and the other $25,000 would come from the SHSP allocation. Any
amount used to manage and administer OPSG that is charged to SHSP may be above and
beyond the $175,000 available to manage the SHSP allocation.
HSGP recipients are also reminded that any M&A charged to a recipient’s or subrecipient’s UASI
funding must be directly allocable to administration of the UASI grant program and cannot be used to
cover M&A costs that are directly allocable to SHSP or OPSG funding. Similarly, any M&A charged to a
recipient’s or subrecipient’s SHSP or OPSG funding cannot be used to cover M&A costs directly
allocable to UASI funding.
Specific for OPSG, subrecipients and friendly forces may retain funding for M&A purposes; however, the
total amount retained cannot exceed 5% of the subrecipient’s subaward. Friendly forces are local law
enforcement entities that are subordinate subrecipients under OPSG. In other words, friendly forces are
entities that receive a subaward from a subrecipient under the OPSG program. Friendly forces must
comply with all requirements of subrecipients under 2 C.F.R. Part 200.
Equipment (SHSP and UASI)
The 21 allowable prevention, protection, mitigation, response, and recovery equipment categories for
HSGP are listed on the Authorized Equipment List (AEL). Some equipment items require prior approval
from FEMA before obligation or purchase of the items. Please reference the grant notes for each
equipment item to ensure prior approval is not required or to ensure prior approval is obtained if
necessary. Recipients and subrecipients may purchase equipment not listed on the AEL, but only if they
first seek and obtain prior approval from FEMA.
Unless otherwise stated, all equipment must meet all mandatory regulatory and/or FEMA-adopted
standards to be eligible for purchase using these funds. In addition, recipients will be responsible for
obtaining and maintaining all necessary certifications and licenses for the requested equipment.
Investments in emergency communications systems and equipment must meet applicable SAFECOM
Guidance recommendations. Such investments must be coordinated with the SWIC and the State
Interoperability Governing Body (SIGB) to ensure interoperability and long-term compatibility. For
personal protective equipment (PPE), recipients are encouraged to give procurement preference to
domestic manufacturers of PPE or PPE raw materials to the maximum practicable and allowed by law.
HSGP Appendix | May 2022 Page A-11
Grant funds may be used for the procurement of medical countermeasures. Procurement of medical
countermeasures must be conducted in collaboration with state, city, or local health departments that
administer federal funds from the Department of Health and Human Services for this purpose and with
existing Metropolitan Medical Response System committees where available, to sustain their long-term
planning for appropriate, rapid, and local medical countermeasures, including antibiotics and antidotes for
nerve agents, cyanide, and other toxins. Procurement must have a sound threat-based justification with an
aim to reduce the consequences of mass casualty incidents during the first crucial hours of a response.
Prior to procuring pharmaceuticals, recipients must have in place an inventory management plan to avoid
large periodic variations in supplies due to coinciding purchase and expiration dates. Recipients are
encouraged to enter into rotational procurement agreements with vendors and distributors. Purchases of
pharmaceuticals must include a budget for the disposal of expired drugs within each fiscal year’s POP for
HSGP. The cost of disposal cannot be carried over to another FEMA grant or grant period.
EMS electronic patient care data systems should comply with the most current data standard of the
National Emergency Medical Services Information System (www.NEMSIS.org).
Recipients are reminded that school hardening is an eligible activity under SHSP and UASI. School
hardening measures include but are not limited to:
• Bullet resistant doors and glass;
• Hinge-locking mechanisms;
• Immediate notification to emergency 911 systems;
• Mechanisms that provide real time actionable intelligence directly to law enforcement and first
responders;
• Installation of distraction devices or other countermeasures administered by law enforcement; and
• Other measures determined to provide significant improvements to schools’ physical security.
Additionally, SHSP and UASI funds may be used for equipment purchases related to state court
cybersecurity, 911 call capabilities, alert and warning capabilities, and implementation of the REAL ID
Act (Pub. L. No. 109-13).
Equipment (OPSG)
OPSG equipment is intended to be incidental to the enhanced border security operations being performed.
The grant is not intended to be used to outfit or supply general equipment to SLTT law enforcement
agencies. Equipment must be relatable to and justified by the operational benefit it will provide. Each
appropriate OPSG sector coordinator is required to keep an inventory of OPSG purchased equipment that
includes at a minimum: 1) grant funding year; 2) purchase amount; 3) purchase date; 4) purchase
quantity; 5) equipment ID; 6) source of funding for the property, including the Federal Award
Identification Number; 7) who holds title to the property; 8) federal share percent of the property; 9)
location of the property; 10) use and condition of the property; 11) disposal date; and 12) brief disposal
justification information and sale price if sold. Each Operations Order/FRAGO will require that each
friendly force submit the equipment inventory for each Operations Order/FRAGO submission.
• Equipment Marking. Because equipment purchased with OPSG funding is intended to be used
to support OPSG activities, it may be appropriately marked to ensure its ready identification and
primary use for that purpose. When practicable, any equipment purchased with OPSG funding
should be prominently marked as follows: "Purchased with DHS funds for Operation
Stonegarden Use."
• Fuel Cost and Mileage Reimbursement. There is no cap for reimbursement of fuel or mileage
costs in support of operational activities. Subrecipients and friendly forces may not claim
reimbursements for both mileage and fuel/maintenance for the same equipment at the same time.
HSGP Appendix | May 2022 Page A-12
• Vehicle and Equipment Acquisition, Including Leasing and Rentals. Allowable purchases
under OPSG include patrol vehicles and other mission-specific equipment whose primary purpose
is to increase operational capabilities on or near a border nexus in support of approved border
security operations. A detailed justification must be submitted to the respective FEMA HQ
Preparedness Officer prior to purchase.
• Medical Emergency Countermeasures. Allowable purchases under OPSG include narcotic
antagonist pharmaceuticals, detection and identification equipment, safe storage and
transportation, personnel protective equipment, and initial equipment training, as reflected in the
AEL and explained in IB 438, Guidance for Use of Operation Stonegarden Funds for Small
Unmanned Aircraft Systems and Certain Costs Related to Transportation and Medical Care,
issued January 31, 2019.
Requirements for Small Unmanned Aircraft System (SHSP, UASI, and OPSG)
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and IB 438 and also include a description of the policies and procedures in place to safeguard
individuals’ privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or
otherwise use the sUAS equipment. SUAS policies are not required at the time of application but must be
received and approved by FEMA prior to obligating HSGP funds. All grant-funded procurements must be
executed in a manner compliant with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327.
For recipients that use HSGP funds for sUAS, FEMA advises that there is a general privacy concern
related to the use of this equipment if the data the devices collect is transmitted to servers not under the
control of the operator. It has been reported that some manufacturers of sUAS encrypt data and send that
data to servers outside the United States. The U.S. Department of Homeland Security’s Privacy Office
suggests the recipient fully explore data transmission and storage issues with vendors to reduce the
possibility of data breaches.
Additionally, the Joint Explanatory Statement (JES) accompanying the FY 2022 DHS Appropriations Act
further requires recipients to certify they have reviewed the Industry Alert on Chinese Manufactured
Unmanned Aircraft Systems, and completed a risk assessment that considers the proposed use of foreign-
made sUAS to ascertain potential risks (e.g., privacy, data breaches, cybersecurity, etc.) related to foreign-
made versus domestic sUAS.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA was alerted of an advisory guidance document issued by DHS, the Department of
Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.
The purpose of the advisory guidance document is to help non-federal public and private entities better
understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate
threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
HSGP Appendix | May 2022 Page A-13
representations of the systems’ legality or functionality. Please also see the DHS press release on this
topic for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-
technology-detect-and-mitigate-unmanned-aircraft.
Training (SHSP and UASI)
Allowable training-related costs under HSGP include the establishment, support, conduct, and attendance of
training specifically identified under the SHSP and UASI program and/or in conjunction with emergency
preparedness training by other federal agencies (e.g., HHS and Department of Transportation [DOT]).
Training conducted using HSGP funds should address a performance gap identified through an Integrated
Preparedness Plan (IPP) or other assessments (e.g., National Emergency Communications Plan [NECP]
Goal Assessments) and contribute to building a capability that will be evaluated through a formal exercise.
Any training or training gaps, including training related to under-represented, diverse populations that may
be more impacted by disasters, including children, seniors, individuals with disabilities or access and
functional needs, individuals with diverse culture and language use, individuals with lower economic
capacity and other underserved populations, should be identified in an IPP and addressed in the state or
high-risk urban area training cycle. Emergency preparedness training related to those training gaps,
including related to under-represented, diverse populations that may be more impacted by disasters, is
allowable. Recipients are encouraged to use existing training rather than developing new courses. When
developing new courses, recipients are encouraged to apply the Analyze, Design, Develop, Implement, and
Evaluate (ADDIE) model of instructional design.
Recipients are also encouraged to utilize FEMA’s National Preparedness Course Catalog. Trainings include
programs or courses developed for and delivered by institutions and organizations funded by FEMA. This
includes the Center for Domestic Preparedness (CDP), the Emergency Management Institute (EMI), and
FEMA’s Training Partner Programs, including the Continuing Training Grants (CTG), the National
Domestic Preparedness Consortium (NDPC), the Rural Domestic Preparedness Consortium (RDPC), and
other partners.
The catalog features a wide range of course topics in multiple delivery modes to meet FEMA’s mission
scope as well as the increasing training needs of federal, state, local, territorial, and tribal audiences. The
catalog can be accessed at http://www.firstrespondertraining.gov.
Some training activities require Environmental and Historic Preservation (EHP) Review, including
exercises, drills or trainings that require any type of land, water, or vegetation disturbance or building of
temporary structures or that are not located at facilities designed to conduct training and exercises.
Additional information on training requirements and EHP review can be found online at:
https://www.fema.gov/media-library/assets/documents/90195.
Exercises (SHSP and UASI)
Exercises conducted with grant funding should be managed and conducted consistent with Homeland
Security Exercise and Evaluation Program (HSEEP). HSEEP guidance for exercise design, development,
conduct, evaluation, and improvement planning is located at https://www.fema.gov/emergency-
managers/national-preparedness/exercises/hseep.
Some exercise activities require EHP review, including exercises, drills or trainings that require any type of
land, water, or vegetation disturbance or building of temporary structures or that are not located at facilities
designed to conduct training and exercises. Additional information on training requirements and EHP
review can be found online at https://www.fema.gov/media-library/assets/documents/90195.
HSGP Appendix | May 2022 Page A-14
Maintenance and Sustainment (SHSP, UASI, and OPSG)
Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses, and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty, and it may only cover equipment purchased with HSGP funds or for equipment dedicated for
HSGP-related purposes. As with warranties and maintenance agreements, this extends to licenses and
user fees as well.
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Except for maintenance plans or extended warranties purchased incidental to the original purchase
of the equipment, the period covered by maintenance or warranty plan must not exceed the POP of the
specific grant funds used to purchase the plan or warranty.
Grant funds are intended to support the Goal by funding projects that build and sustain the core
capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from
those threats that pose the greatest risk to the security of the Nation. In order to provide recipients the
ability to meet this objective, the policy set forth in FEMA’s IB 379, Guidance to State Administrative
Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding, initially for FY 2007-2011,
allows for the expansion of eligible maintenance and sustainment costs which must be in (1) direct
support of existing capabilities; (2) must be an otherwise allowable expenditure under the applicable grant
program; (3) be tied to one of the core capabilities in the five mission areas contained within the Goal,
and (4) shareable through the EMAC. Additionally, eligible costs may also be in support of equipment,
training, and critical resources that have previously been purchased with either federal grant or any other
source of funding other than FEMA preparedness grant program dollars.
Law Enforcement Terrorism Prevention Activities Allowable Costs (SHSP and UASI)
When identifying and selecting projects to meet the Law Enforcement Terrorism Prevention Activities
(LETPA) set-aside requirement, recipients are strongly encouraged to consult with the law enforcement
community and to consider the capabilities and resource requirements of law enforcement agencies and
their unique and central role in preventing and protecting against acts of terrorism. LETPAs can also
support a National Priority Area (e.g., an investment can be counted as supporting both the Soft
Targets/Crowded Places and LETPA minimum allocation requirements, if applicable). Note: for FY
2022, the LETPA set-aside requirement is 30% of SHSP and UASI awards, which is an increase
from 25% in previous years. In particular, recipients should consider investing in projects such as:
• Maturation and enhancement of designated state and major urban area fusion centers, including
information sharing and analysis, threat recognition, terrorist interdiction, and intelligence
analyst training and salaries (subject to certain conditions);
• Regional counterterrorism training programs for small, medium, and large jurisdictions to
exchange information and discuss the current threat environment, lessons learned, and best
practices to help prevent, protect against, and mitigate acts of terrorism;
• Support for coordination of regional full-scale training exercises (federal, state, and local law
enforcement participation) focused on terrorism-related events; and
HSGP Appendix | May 2022 Page A-15
• Law enforcement Chemical, Biological, Radiological, Nuclear, and high yield Explosives
detection and response capabilities, such as bomb detection/disposal capability deployment,
sustainment, or enhancement, including canine teams, robotics platforms, and x-ray technology.
Additional examples of allowable LETPA projects include but are not limited to:
• Coordination between fusion centers and other intelligence, operational, analytic, or
investigative efforts including, but not limited to JTTFs, Field Intelligence Groups (FIGs), High-
Intensity Drug Trafficking Areas (HIDTA), Regional Information Sharing Systems (RISS)
Centers, criminal intelligence units, real-time crime analysis centers and DHS intelligence,
operational, analytic, and investigative entities;
• Implementation and maintenance of the Nationwide Suspicious Activity Reporting (SAR)
Initiative (NSI), including training for front-line personnel on identifying and reporting
suspicious activities, tips/leads, and online/social media-based threats, as well as the execution
and management of threat assessment programs to identify, evaluate, and analyze indicators and
behaviors indicative of terrorism, targeted violence, threats to life, and other criminal activity;
• Management and operation of activities that support the execution of the intelligence process
and fusion centers, including but not limited to: Fusion Liaison Officer (FLO) programs,
security programs to protect the facility, personnel, and information, and the protection of
privacy, civil rights, and civil liberties;
• Implementation of the “If You See Something, Say Something®” campaign to raise public
awareness of indicators of terrorism and terrorism-related crime and associated efforts to
increase the sharing of information with public and private sector partners, including nonprofit
organizations. Note: DHS requires that all public and private sector partners wanting to
implement and/or expand the DHS “If You See Something, Say Something®” campaign using
grant funds work directly with the DHS Office of Partnership and Engagement (OPE) to ensure
all public awareness materials (e.g., videos, posters, tri-folds, etc.) are consistent with DHS’s
messaging and strategy for the campaign and compliant with the initiative’s trademark, which is
licensed to DHS by the New York Metropolitan Transportation Authority. Coordination with
OPE, through the Campaign’s Office (seesay@hq.dhs.gov), must be facilitated by the FEMA
HQ Preparedness Officer;
• Increase physical security, through law enforcement personnel and other protective measures,
by implementing preventive and protective measures at critical infrastructure sites or at-risk
nonprofit organizations;
• Building and sustaining preventive radiological and nuclear detection capabilities, including
those developed through the Securing the Cities initiative;
• Integration and interoperability of systems and data, such as computer aided dispatch (CAD)
and record management systems (RMS), to facilitate the collection, evaluation, and assessment
of suspicious activity reports, tips/leads, and online/social media-based threats; and
• Development of countering violent extremism programs, projects, and initiatives, addressing
prevention, intervention, and diversion efforts, including training on roles of law enforcement
and how to effectively partner with law enforcement; developing and promoting training
specifically for law enforcement executives and frontline officers on potential behaviors and
indicators of violent extremism and how to appropriately analyze and report them; supporting
community and law enforcement engagement strategies such as table top exercises, roundtable
events, town hall meetings, and peer to peer activities; funding for existing and/or expansion of
law enforcement community relations efforts, support for the development of community
engagement plans, and joint projects to increase the awareness of violent extremist threats and
community mitigation solutions.
HSGP Appendix | May 2022 Page A-16
Law Enforcement Readiness (SHSP, UASI, and OPSG)
OPSG grant funds may be used to increase operational, material, and technological readiness of SLTT
law enforcement agencies. The Delegation of Immigration Authority, Section 287(g) of the Immigration
and Nationality Act (INA) program allows a state or local law enforcement entity to enter into a
partnership with Immigration and Customs Enforcement (ICE), under a joint Memorandum of Agreement
(MOA), to receive delegated authority for immigration enforcement within their jurisdictions.
SHSP, UASI, or OPSG grant funds may be requested and may be approved on a case-by-case basis for
immigration enforcement training in support of the border security mission. Requests for training will be
evaluated on a case-by-case basis and can only be used for certification in the section 287(g) program
provided by DHS/ICE. SHSP, UASI, or OPSG subrecipients with agreements under section 287(g) of the
INA (8 U.S.C. § 1357(g)) to receive delegated authority for immigration enforcement within their
jurisdictions may also be reimbursed for section 287(g) related operational activities with approval from
FEMA on a case-by-case basis. For OPSG, subrecipients must be authorized by USBP Headquarters and
Sectors, and operational activities must be coordinated through a USBP Sector.
Regional Border Projects (OPSG)
Recipients are encouraged to prioritize the acquisition and development of regional projects on the
borders to maximize interoperability and coordination capabilities among federal agencies and with state,
local, and tribal law enforcement partners. Such regional projects include:
• Communications equipment;
• Radio systems and repeaters;
• Integration with regional intelligence and information sharing effort (i.e., fusion centers):
o Intelligence analysts.
• Situational Awareness equipment:
o License Plate Reader Networks;
o Visual detection and surveillance systems;
o Sensor Systems;
o Radar Systems (for air and/or marine incursions); and
o Aircraft systems (manned or unmanned).
Critical Emergency Supplies (SHSP and UASI)
Critical emergency supplies, such as shelf stable products, water, and medical equipment and supplies are
an allowable expense under SHSP and UASI. Prior to the allocation of grant funds for stockpiling
purposes, each state must have FEMA’s approval of a five-year viable inventory management plan, which
should include a distribution strategy and related sustainment costs if planned grant expenditure is over
$100,000.00.
If grant expenditures exceed the minimum threshold, the five-year inventory management plan will be
developed by the recipient and monitored by FEMA. FEMA will provide program oversight and technical
assistance as it relates to the purchase of critical emergency supplies under UASI. FEMA will establish
guidelines and requirements for the purchase of these supplies under UASI and monitor development and
status of the state’s inventory management plan.
SAAs (through their state Emergency Management Office) are strongly encouraged to consult with their
respective FEMA Regional Logistics Chief regarding disaster logistics-related issues. States are further
encouraged to share their FEMA approved plan with local jurisdictions and tribes.
HSGP Appendix | May 2022 Page A-17
Construction and Renovation (SHSP and UASI)
Project construction using SHSP and UASI funds may not exceed the greater of $1 million or 15% of the
grant award. For the purposes of the limitations on funding levels, communications towers are not
considered construction. See guidance on communication towers below.
All construction and renovation projects require EHP review. Recipients and subrecipients are
encouraged to have completed as many steps as possible for a successful EHP review in support of their
proposal for funding (e.g., coordination with their State Historic Preservation Office to identify potential
historic preservation issues and to discuss the potential for project effects, compliance with all state and
local EHP laws and requirements). Projects for which the recipient believes an Environmental
Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01, Rev 01, FEMA
Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness
Officer within six months of the award and completed EHP review materials must be submitted no later
than 12 months before the end of the period of performance. EHP policy guidance and the EHP Screening
Form, can be found online at: https://www.fema.gov/media-library/assets/documents/90195. EHP review
materials should be sent to gpdehpinfo@fema.dhs.gov.
Written approval must be provided by FEMA prior to the use of any HSGP funds for construction or
renovation. When applying for construction funds, recipients must submit evidence of approved zoning
ordinances, architectural plans, and any other locally required planning permits. Additionally, recipients
are required to submit a SF-424C form with budget detail citing the project costs, and an SF-424D Form
for standard assurances for the construction project.
Recipients using funds for construction projects must comply with the Davis-Bacon Act (codified as
amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. §
5196(j)(9), which cross-references Davis-Bacon). Recipients must ensure that their contractors or
subcontractors for construction projects pay workers no less than the prevailing wages for laborers and
mechanics employed on projects of a character like the contract work in the civil subdivision of the state
in which the work is to be performed. Additional information regarding compliance with the Davis-Bacon
Act, including Department of Labor (DOL) wage determinations, is available online at
https://www.dol.gov/whd/govcontracts/dbra.htm.
Construction and Renovation (OPSG)
OPSG funds may not be used for any construction.
Communications Towers
All construction of communication towers requires EHP review. When applying for funds to construct
communication towers, recipients and subrecipients must submit evidence that the Federal
Communication Commission’s Section 106 of the National Historic Preservation Act, Pub. L. No. 89-
665, as amended, review process has been completed and submit all documentation resulting from that
review to FEMA with a GPD EHP Screening Form and supporting materials for EHP review. Recipients
and subrecipients are encouraged to have completed as many steps as possible for a successful EHP
review in support of their proposal for funding (e.g., coordination with their State Historic Preservation
Office to identify potential historic preservation issues and to discuss the potential for project effects,
compliance with all state and local EHP laws and requirements). Projects for which the recipient believes
an EA may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, FEMA
Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness
Officer within six months of the award and completed EHP review materials must be submitted no later
than 12 months before the end of the period of performance. EHP policy guidance and the EHP Screening
HSGP Appendix | May 2022 Page A-18
Form, can be found online at: https://www.fema.gov/media-library/assets/documents/90195. EHP review
materials should be sent to gpdehpinfo@fema.dhs.gov.
Western Hemispheric Travel Initiative (SHSP)
In addition to the expenditures outlined above, SHSP funds may be used to support the implementation
activities associated with the Western Hemisphere Travel Initiative (WHTI), including the issuance of
WHTI-compliant tribal identification cards.
Emergency Management Accreditation Program
States can encourage their local jurisdictions to pursue assessment and accreditation under the Emergency
Management Accreditation Program (EMAP). EMAP’s assessment and accreditation of emergency
management organizations against consensus-based, American National Standards Institute (ANSI)-
certified standards allows for standardized benchmarking of critical functions necessary for an emergency
management organization to meet the core capabilities identified in the Goal. Additional information on
the EMAP Standard is available at http://www.emap.org.
28 C.F.R. Part 23 Guidance
FEMA requires that any information technology system funded or supported by these funds comply with
28 C.F.R. Part 23, Criminal Intelligence Systems Operating Policies if this regulation is determined to be
applicable. Additionally, please see 28 C.F.R. Part 23 requirements that pertain to fusion centers at
http://www.dhs.gov/homeland-security-grant-programs-hsgp.
Unallowable Costs (OPSG)
OPSG unallowable costs include costs associated with evidence collection, arrest processing, prosecution,
and Traffic/DUI checkpoints, such as evidence documentation cameras, fingerprinting supplies, alcohol
breathalyzers, portable work lights, traffic barricades, and similar law enforcement expenses. OPSG
unallowable costs also include costs associated with staffing and general IT computing equipment and
hardware, such as personal computers, faxes, copy machines, modems, etc. OPSG is not intended as a
hiring program. Therefore, applying funds toward hiring full-time or permanent sworn public safety
officers is unallowable. OPSG funding shall not be used to supplant inherent routine patrols and law
enforcement operations or activities not directly related to providing enhanced coordination between local
and federal law enforcement agencies. Finally, construction and/or renovation costs are prohibited under
OPSG. Applicants should refer to IB 421b, or contact their FEMA HQ Preparedness Officer for guidance
and clarification. Due to the nature of OPSG, exercise expenses are not allowable costs under OPSG.
Unallowable Costs (SHSP, UASI, and OPSG)
• Per FEMA policy, the purchase of weapons and weapons accessories, including ammunition, is
not allowed with HSGP funds;
• Grant funds may not be used for the purchase of equipment not approved by FEMA. Grant funds
must comply with IB 426 and may not be used for the purchase of the following equipment:
firearms; ammunition; grenade launchers; bayonets; or weaponized aircraft, vessels, or vehicles of
any kind with weapons installed;
• Unauthorized exercise-related costs include:
o Reimbursement for the maintenance or wear and tear costs of general use vehicles (e.g.,
construction vehicles), medical supplies, and emergency response apparatus (e.g., fire
trucks, ambulances); and
o Equipment that is purchased for permanent installation and/or use, beyond the scope of
the conclusion of the exercise (e.g., electronic messaging sign).
HSGP Appendix | May 2022 Page A-19
Indirect (Facilities and Administrative [F&A]) Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
Resources for Planning, Training, and Exercising (SHSP, UASI, and OPSG)
Planning Assistance
FEMA’s National Preparedness Directorate (NPD) offers technical assistance (TA) that is designed to
provide recipients and subrecipients with specialized expertise to improve and enhance the continuing
development of state and local emergency management across the five mission areas of the Goal and
across all core capabilities. TA provides the opportunity to engage emergency managers, emergency
planners, and appropriate decision-makers in open discussion of options to improve plans and planning
considering their jurisdiction’s needs. Although there is no direct cost to approved jurisdictions for FEMA
TA, jurisdictions are expected to invest staff resources and take ownership of the resulting products and
tools.
TA deliveries combine current emergency management best practices with practical consideration of
emerging trends, through discussion facilitated by FEMA contract specialists and with the support of
FEMA Region operational specialists. Additionally, peer-to-peer representation may also be included
from other jurisdictions that have recently addressed the same planning issue. The TA request form can be
accessed at https://www.fema.gov/emergency-managers/nims/implementation-training.
Training Information
Per IB 432, Review and Approval Requirements for Training Courses Funded Through Preparedness
Grants, issued on July 19, 2018, states, territories, tribal entities, and high-risk urban areas are no longer
required to request approval from FEMA for personnel to attend non-DHS FEMA training as long as the
training is coordinated with and approved by the state, territory, tribal, or high-risk urban area Training
Point of Contact (TPOC) and falls within the FEMA mission scope and the jurisdiction’s EOP. For
additional information on review and approval requirements for training courses funded with
preparedness grants, please refer to Information Bulletin (IB) 426, Guidance to Recipients and
Subrecipients of FEMA Preparedness Grants Regarding the Implementation of Executive Order 13809
Restoring State, Tribal, and Local Law Enforcement’s Access to Life-Saving Equipment and Resources
(Nov. 1, 2017).
FEMA will conduct periodic reviews of all state, local, territory, tribal entities, and high-risk urban area
training funded by FEMA. These reviews may include requests for all course materials and physical
observation of, or participation in, the funded training. If these reviews determine that courses are outside
the scope of this guidance, recipients will be asked to repay grant funds expended in support of those
efforts. For further information on developing courses using the instructional design methodology and
HSGP Appendix | May 2022 Page A-20
tools that can facilitate the process, SAAs and TPOCs are encouraged to review the National Training and
Education Division Responder Training Development Center (RTDC) website.
Some training and exercise activities require EHP Review, including exercises, drills or trainings that
require any type of land, water, or vegetation disturbance or building of temporary structures or that are not
located at facilities designed to conduct training and exercises. Additional information on training
requirements and EHP review can be found online at https://www.fema.gov/media-
library/assets/documents/90195.
DHS/FEMA Provided Training and Education
FEMA offers tuition-free training and education programs and courses through several providers including
the CDP, EMI, and the National Training and Education Division’s Training Partners Program (TPP). TPP
includes the Center for Homeland Defense and Security, NDPC, RDPC, and the CTG Program.
FEMA’s National Preparedness Course Catalog
This online searchable catalog features a wide range of course topics in multiple delivery modes to meet
FEMA’s mission scope as well as the increasing training needs of federal, state, local, territorial, and tribal
audiences. The catalog can be accessed at http://www.firstrespondertraining.gov.
Training Not Provided by DHS/FEMA
These trainings include courses that are either state-sponsored or federal-sponsored (non-DHS/FEMA),
coordinated and approved by the SAA or their designated TPOC, and fall within the FEMA mission scope
to prepare SLTT personnel to prevent, protect against, mitigate, respond to, and recover from acts of
terrorism or catastrophic events.
• State Sponsored Courses. These courses are developed for and/or delivered by institutions or
organizations other than federal entities or FEMA and are sponsored by the SAA or their
designated TPOC.
• Joint Training and Exercises with the Public and Private Sectors. These courses are sponsored
and coordinated by private sector entities to enhance public-private partnerships for training
personnel to prevent, protect against, mitigate, respond to, and recover from acts of terrorism or
catastrophic events. In addition, states, territories, tribes, and high-risk urban areas are
encouraged to incorporate the private sector in government- sponsored training and exercises.
Additional information on both FEMA provided training and other federal and state training can be found
at http://www.firstrespondertraining.gov.
Training Information Reporting System (“Web-Forms”)
Web-Forms is an electronic data management system built to assist SAA TPOCs and federal agencies
with submitting non-National Training and Education Division provided training courses for inclusion in
the State/Federal-Sponsored Course Catalog through electronic forms. The information collected is used
in a two-step review process to ensure the training programs adhere to the intent of the HSGP guidance
and the course content is structurally sound and current. As these programs may be delivered nationwide,
it is vital to ensure each training program’s viability and relevance to the Homeland Security mission.
Reporting training activities through Web-Forms is not required under present funding. However, the
system remains available and can be accessed through the Web-Forms section of the FEMA National
Preparedness Course Catalog to support recipients in their own tracking of training deliveries.
HSGP Appendix | May 2022 Page A-21
Exercise Information
Recipients that use HSGP funds to conduct an exercise(s) are encouraged to complete a progressive
exercise series. Exercises conducted by states and high-risk urban areas may be used to fulfill similar
exercise requirements required by other grant programs. Recipients are encouraged to invite
representatives/planners involved with other federally mandated or private exercise activities. States and
high-risk urban areas are encouraged to share, at a minimum, the multi- year training and exercise
schedule with those departments, agencies, and organizations included in the plan.
• Validating Capabilities. Exercises examine and validate capabilities-based planning across the
Prevention, Protection, Mitigation, Response, and Recovery mission areas. The extensive
engagement of the whole community, including but not limited to examining the needs and
requirements for individuals with disabilities, individuals with limited English proficiency, and
others with access and functional needs, is essential to the development of an effective and
comprehensive exercise program. Exercises are designed to be progressive – increasing in scope
and complexity and drawing upon results and outcomes from prior exercises and real-world
incidents – to challenge participating communities. Consistent with HSEEP guidance and tools,
the National Exercise Program (NEP) serves as the principal exercise mechanism for examining
national preparedness and measuring readiness. Exercises should align with priorities and
capabilities identified in a multi-year IPP.
• Special Event Planning. If a state or high-risk urban area will be hosting a special event (e.g.,
Super Bowl, G-8 Summit), the special event planning should be considered as a training or
exercise activity for the multi-year IPP. States must include all confirmed or planned special
events in the multi-year IPP. The state or high-risk urban area may plan to use SHSP or UASI
funding to finance training and exercise activities in preparation for those events. States and
high-risk urban areas should also consider exercises at major venues (e.g., arenas, convention
centers) that focus on evacuations, communications, and command and control.
• Regional Exercises. States should also anticipate participating in at least one regional exercise
annually.
• Role of Non-Governmental Entities in Exercises. Non-governmental participation in all levels of
exercises is strongly encouraged. Leaders from non-governmental entities should be included in
the planning, design, and evaluation of an exercise. SLTT jurisdictions are encouraged to
develop exercises that test the integration and use of resources provided by non-governmental
entities, defined as the private sector and private non-profit, faith-based, and community
organizations. Participation in exercises should be coordinated with local Citizen Corps Whole
Community Council(s) or their equivalents and other partner agencies.
Reporting on the Implementation of the National Preparedness
System
Identifying and Assessing Risk and Estimating Capability Requirements
By December 31, 2022, states, territories, and high-risk urban areas are required to complete a
THIRA/SPR that addresses all 32 core capabilities and is compliant with CPG 201, Third Edition.
Beginning in 2020, jurisdictions began the requirement to respond to a series of planning-related
questions as part of the THIRA/SPR.
Jurisdictions are required to submit a THIRA every three years to establish a consistent baseline for
assessment. While the THIRA is only required every three years, jurisdictions are required to submit an
SPR annually. For additional guidance on the THIRA/SPR, please refer to Comprehensive Preparedness
Guide (CPG) 201, Third Edition.
HSGP Appendix | May 2022 Page A-22
Reporting
• States and territories will submit their THIRA and SPR through the Unified Reporting Tool
(URT) on Prep Toolkit no later than December 31 of the applicable year (every three years for
THIRA and each year for SPR).
• High-risk urban areas that receive UASI funding will submit their THIRA/SPR through the URT
on Prep Toolkit no later than December 31 for the years they have UASI open grants. If a UASI
recipient has completed closeout for their UASI grant award period of performance, they do not
have to submit a THIRA/SPR as the requirement is not applicable to closed grant awards.
• States, territories, and high-risk urban areas should work collaboratively to create the most
accurate THIRA and SPR possible. States, territories, and high-risk urban areas may share
scenarios, targets, and assessed capabilities when appropriate.
• Please contact FEMA-SPR@fema.dhs.gov if you have questions.
Building and Sustaining Capabilities
States, territories, and high-risk urban areas must prioritize and align SHSP and UASI grant funding
investments in building and sustaining capabilities in areas that align with the national priorities in the
annual HSGP NOFO and capability gaps identified in their THIRA and SPR.
Reporting
In each HSGP recipient’s Biannual Strategy and Implementation Report (BSIR), as part of programmatic
monitoring, the recipient must describe how expenditures support closing capability gaps or sustaining
capabilities identified in the THIRA and SPR. HSGP recipients must, on a project-by-project basis, check
one of the following:
• Building a capability with HSGP funding; and
• Sustaining a capability with HSGP funding.
National Incident Management System (NIMS) Implementation
Recipients receiving HSGP funding are required to implement NIMS. NIMS guides all levels of
government, nongovernmental organizations (NGO), and the private sector to work together to prevent,
protect against, mitigate, respond to, and recover from incidents. NIMS provides stakeholders across the
whole community with the shared vocabulary, systems, and processes to successfully deliver the
capabilities described in the National Preparedness System. HSGP recipients must use standardized
resource management concepts for resource typing, credentialing, and an inventory to facilitate the
effective identification, dispatch, deployment, tracking, and recovery of resources.
The NIMS Implementation Objectives for Local, State, Tribal, and Territorial Jurisdictions clarify the
NIMS implementation requirements in FEMA preparedness grant NOFOs. As recipients and
subrecipients of federal preparedness (non-disaster) grant awards, jurisdictions and organizations must
achieve, or be actively working to achieve, all of the NIMS Implementation Objectives. The objectives
can be found on the NIMS webpage at https://www.fema.gov/emergency-managers/nims/implementation-
training.
Reporting
• Recipients report in the applicable secondary NIMS assessment portion of the URT as part of
their THIRA/SPR submission, as outlined in the HSGP NOFO.
Planning to Deliver Capabilities
Recipients shall develop and maintain, jurisdiction-wide, all threats and hazards EOPs consistent with
Comprehensive Preparedness Guide 101, Version 2.0 (CPG 101 v2), Developing and Maintaining
HSGP Appendix | May 2022 Page A-23
Emergency Operations Plans (November 2010). Recipients must update their EOPs at least once every
two years.
Reporting
• Recipients report EOP compliance with CPG 101 v2 by completing the secondary CPG-101
assessment as part of their THIRA/SPR submission in the URT.3
Validating Capabilities
All recipients will develop and maintain a progressive exercise program consistent with HSEEP guidance
in support of the NEP. The NEP serves as the principal exercise mechanism for examining national
preparedness and measuring readiness. The NEP is a two-year cycle of exercises across the nation that
validates capabilities in all preparedness mission areas. The two-year NEP cycle is guided by Principals’
Strategic Priorities, established by the National Security Council, and informed by preparedness data from
jurisdictions across the Nation.
To develop and maintain a progressive exercise program consistent with HSEEP and in support of the
NEP, recipients should engage senior leaders and other whole community stakeholders to identify
preparedness priorities. These priorities should be informed by various factors, including jurisdiction-
specific threats and hazards (i.e., the THIRA); areas for improvement identified by real-world events and
exercises; external requirements such as state or national preparedness reports, homeland security policy,
and industry reports; and accreditation standards, regulations, or legislative requirements. Recipients
should document these priorities and use them to deploy a schedule of preparedness events in a multi-year
IPP. Information related to Integrated Preparedness Planning Workshops (IPPWs) can be found on the
HSEEP website at https://www.fema.gov/emergency-managers/national-preparedness/exercises/hseep
and https://preptoolkit.fema.gov/.
The NEP provides exercise sponsors the opportunity to receive exercise design and delivery assistance,
tools and resources, enhanced coordination, and the ability to directly influence and inform policy and
preparedness programs. If you have any questions, or would like to request assistance through the NEP,
please visit the NEP website at: https://www.fema.gov/national-exercise-program, or reach out to the
National Exercise Program directly at NEP@fema.dhs.gov.
• Recipients must have a current multi-year IPP that identifies preparedness priorities and
activities. The current multi-year IPP must be submitted to hseep@fema.dhs.gov before January
31 of each year:
o Recipients are encouraged to enter their exercise information into the Preparedness
Toolkit at https://preptoolkit.fema.gov/.
• Recipients must submit After-Action Report (AAR)/Improvement Plans (IPs) to
hseep@fema.dhs.gov and indicate which fiscal year’s funds were used (if applicable);
• Submission of AAR/IPs must take place within 90 days following completion of the single
exercise or progressive series:
o Recipients are encouraged to submit AAR/IPs reflecting tabletop exercises that validate
critical plans or those reflecting large-scale functional or full-scale exercises that took
place at the state, territorial, tribal, or UASI level. Recipients are discouraged from
submitting AAR/IPs specific to local jurisdictions that reflect drills;
o If a recipient endures a significant real-world incident during the calendar year that
delays or prevents conduct of a grant-funded exercise, they can submit the AAR from
that event in place of the exercise AARs. Jurisdictions submitting real world AARs
should include an explanation with the AAR submission to hseep@fema.dhs.gov; and
HSGP Appendix | May 2022 Page A-24
o Recipients can access a sample AAR/IP template at:
https://preptoolkit.fema.gov/web/hseep-resources/improvement-planning.
Fusion Centers
A critical component of the national response to the 9/11 terrorist attacks was the development of a
national-level, decentralized, and coordinated terrorism-related information sharing environment (ISE).
State and local governments, supported by federal investments from DHS, the Department of Justice
(DOJ), Department of Health and Human Services (HHS), and other federal agencies, established the
National Network of Fusion Centers (National Network), which became the backbone of the national ISE.
This National Network, comprised of 80 state and major urban area fusion centers, collaborates and
shares information with partners from all levels of government and the private sector, as well as other
field-based information sharing partners, including HIDTAs, RISS Centers, JTTFs, major city/county
intelligence units, and real-time crime analysis centers, among others.
National Network participation in NSI enables fusion centers to identify, receive and analyze suspicious
activity reporting and other tips/leads from frontline public safety personnel, the private sector, and the
public, and ensure the sharing of SARs with DHS and the FBI’s JTTFs for further investigation. In
addition to those activities identified in the National Prevention Framework, fusion centers are also
required to collaborate with those intelligence, operational, analytic, investigative, and information-
sharing focused entities to combat a wide array of threats – noted below – in support of efforts to enhance
capabilities for detecting, deterring, disrupting, and preventing acts of terrorism, targeted violence, and
other threats. Such entities include, but are not limited to JTTFs, Area Maritime Security Committees,
Border Enforcement Security Task Forces, Integrated Border Enforcement Teams, HIDTAs, and RISS
Centers as well as other federal intelligence, operational, analytic, and investigative entities. Applicants
should describe their collaboration plan and proposed efforts in their required Fusion Center project as
part of the Intelligence and Information Sharing National Priority.
Today’s threats—including international and domestic terrorism, drugs, gangs, active shooters, targeted
violence, transnational organized crime, and cyber—require federal, state, and local governments to
leverage this national capacity to effectively respond to the evolving nature of the various national and
homeland security threats confronting our Nation. Ultimately, timely identification and analysis of key
indicators from local, state, and federal partners will enable all stakeholders to address threats and
develop and implement data-driven strategies to prevent, protect against, mitigate, and respond
effectively, while ensuring the protection of privacy, civil rights, and civil liberties.
To underscore the importance of the National Network as a critical component of our Nation’s distributed
homeland security and counterterrorism architecture, FEMA preparedness grants will continue to
prioritize support for designated fusion centers (http://www.dhs.gov/fusion-center-locations-and-contact-
information) and the maturation of the ISE. Fusion centers must prioritize the following capabilities to
further enable and mature this national asset and strengthen the collective capacity to identify, collect,
analyze, and share information, and to disseminate actionable and strategic intelligence to key
stakeholders:
• Addressing Threats: Fusion centers provide a national level, decentralized, and coordinated ISE
across all levels of government and disciplines that can be leveraged and applied to address
threats to homeland security, national security, public safety, and/or public health, and especially
those threats that may have little or no warning. Fusion centers should leverage and build upon
their terrorism-focused analytic and information-sharing capabilities so they can be applied to
address threats across the DHS mission space, including threats from both international terrorism
HSGP Appendix | May 2022 Page A-25
and domestic violent extremists, threats to life and targeted violence, transnational organized
criminal activity, cyber threats, and natural hazards, among others that require close collaboration
with DHS operational, investigative, and analytic entities such as CBP, ICE, United States Secret
Service (USSS), CISA, the United States Coast Guard (USCG), and FEMA.
• Analytic Capability: Fusion centers must maintain strong analytic capabilities at tactical,
operational, and strategic levels to address a wide array of threats or hazards that could have
implications for homeland security or national security. These capabilities directly support
operational, investigative, and information sharing efforts across all levels of government. These
capabilities include, but are not limited to:
o Building and sustaining a capable workforce of analysts who have the necessary
experience and training; access to open source, unclassified and classified information,
products, data, suspicious activity reporting; tips/leads and online/social media-based
threats; as well as necessary services and technology to facilitate analytic capabilities and
collaboration;
o Assessing, evaluating, and deconflicting acts of targeted violence, threats to life, and
other criminal or suspicious activity, to include potential indicators and behaviors, for
potential connection to or implications for international or domestic terrorism, or other
threats within the DHS mission space;
o Providing analytic support and responses to requests for information from federal, state,
and local partners during no notice threats, attacks, or incidents, as well as other planned
events such as NSSEs;
o Conducting threat assessments within their respective jurisdictions, including the
identification of threats, intelligence gaps, and mitigation efforts;
o Establishing, formalizing, and maintaining bi-directional information sharing with federal
and other state agencies in accordance with jurisdictional authorities;
o Leveraging available resources and capabilities to conduct target and event deconfliction
in support of threat identification, officer safety, and information sharing.
o Maintaining an ability to routinely support federal government efforts to watchlist
terrorists and transnational organized crime actors; and
o Appropriately planning for, and assessing/forecasting, prioritizing, and executing against
both known and emerging threat vectors, and ensuring the safety and security of all
operations, while protecting privacy, civil rights, and civil liberties.
Fusion centers should also consider their operational capacity when aligning manpower and
resources in support of this capability (e.g., the ability to maintain watch and analytic support
functions over a 24/7 operational tempo).
• Technological Integration: Access to data, information, and products is essential for fusion
centers and the federal government to effectively identify, collect, analyze, and share information.
Just as threats do not stop at jurisdictional borders, fusion centers must be able to effectively
access and share appropriate information and data across jurisdictions, agencies, and disciplines.
Fusion centers must ensure and certify via the Fusion Center Assessment they have the
necessary technological capacity to access, analyze, and share information, including criminal
intelligence and online/social media threat information, both within their jurisdictions, as well as
with other fusion centers across the country and with the Federal Government through a variety
of systems, databases, tools, and technologies that allow for federated searching and
data/information analysis that protects Personally Identifiable Information and includes
appropriate security, privacy, civil rights, and civil liberties protections. This includes
maintenance of the ability to collect, integrate, evaluate, and assess SAR, tips/leads, data resident
in CAD and RMS, and online/social media-based threats from agencies across the jurisdiction.
Such approaches should also address the evaluation and use of emerging capabilities, including
social network analysis, federated search technology across CAD, RMS, and other data systems,
HSGP Appendix | May 2022 Page A-26
complex data indexing, social media, open source, facial recognition, unmanned aircraft systems,
geographic information systems (GIS), license plate reader technologies, and other artificial
intelligence technologies.
• Interagency Collaboration: Fusion centers must maintain strong partnerships to enable
intelligence, operational, investigative, and analytic collaboration and deconfliction of threat
information with other partners located within their jurisdiction and across their region, including
HIDTAs, RISS Centers, DHS intelligence, operational, investigative, and analytic entities, FBI
Field Offices, JTTFs, and major city/county intelligence units.
State and urban area fusion centers receiving SHSP or UASI grant funds will be evaluated based on
compliance with the guidance and requirements for the National Network as set forth by DHS
Intelligence and Analysis (I&A) through the annual Fusion Center Assessment.
• Additional fusion center grant requirements are listed at http://www.dhs.gov/homeland-security-
grant-program-hsgp.
• FEMA approved analyst courses that meet the grant requirement are listed at
http://www.dhs.gov/fema-approved-intelligence-analyst-training-courses.
Through the Program Performance Report (PPR), fusion centers will report on the compliance with
measurement requirements within the fusion centers through the annual Fusion Center Assessment
managed by DHS I&A and reported to FEMA. In addition to the activities identified in the National
Prevention Framework, fusion centers are also required to collaborate with those analytic, investigative,
and information-sharing entities focused on preventing, detecting, deterring, and disrupting acts of
terrorism and combating transnational criminal organizations. Such entities include, but are not limited to
JTTFs, Area Maritime Security Committees, Border Enforcement Security Task Forces, Integrated
Border Enforcement Teams, HIDTAs, and RISS Centers, as well as other federal intelligence,
operational, analytic, and investigative entities. Applicants will be required to provide information
regarding their information sharing partnerships, including how they will identify, address, and
overcome any existing laws, policies, and practices that prevent information sharing, via the
Information and Intelligence National Priority Investment and supporting data via the annual
Fusion Center Assessment.
Fusion Center Performance Measures
Reference
Number Performance Measures
2022.1 Percentage of federal Information Intelligence Reports (IIRs) originating from fusion center
information that address a specific Intelligence Community need
2022.2 Percentage of federal IIRs originating from fusion center information that the Intelligence
Community otherwise used in performing its mission (e.g., contained first-time reporting;
corroborated existing information; addressed a critical intelligence gap; or helped to define an issue
or target)
2022.3 Number of SARs vetted and submitted by fusion centers that result in the initiation or enhancement
of an investigation by the FBI
2022.4 Number of SAR vetted and submitted by fusion centers that involve an individual on the Watchlist
2022.5 Percentage of Requests for Information (RFIs) from the Terrorist Screening Center (TSC) for which
fusion centers provided information for a TSC case file
2022.6 Percentage of I&A Watchlist nominations that were initiated or updated existing case files based on
information provided by fusion centers
HSGP Appendix | May 2022 Page A-27
Reference
Number Performance Measures
2022.7 Number of distributable analytic products co-authored by one or more fusion centers and/or federal
agencies
2022.8 Percentage of fusion center distributable analytic products that address Homeland Security topics
2022.9 Percentage of fusion center distributable analytic products that address state/local customer
information needs
2022.10 Percentage of key customers reporting that fusion center products are relevant
2022.11 Percentage of key customers reporting that fusion center services are relevant
2022.12 Percentage of key customers reporting that fusion center products are timely for mission needs
2022.13 Percentage of key customers reporting that fusion center services are timely for mission needs
2022.14 Percentage of key customers reporting that fusion center products influenced their decision making
related to threat response activities within their AOR
2022.15 Percentage of key customers reporting that fusion center services influenced their decision making
related to threat response activities within their AOR
2022.16 Percentage of key customers reporting that fusion center products resulted in increased situational
awareness of threats within their AOR
2022.17 Percentage of key customers reporting that fusion center services resulted in increased situational
awareness of threats within their AOR
2022.18 Number of tips and leads vetted by the fusion center
2022.19 Number of tips and leads vetted by the fusion center that were provided to other F/SLTT agencies
for follow up action
2022.20 Number of responses to RFIs from all sources
2022.21 Number of situational awareness products developed and disseminated by fusion centers
2022.22 Number of case support and/or tactical products developed and disseminated by fusion centers
2022.23 Percentage of federally designated special events in which fusion centers played a direct role
2022.24 Percentage of federally declared disasters in which fusion centers played a direct role
2022.25 Number of public safety incidents in which fusion centers played a direct role
Continuity Capability
Continuity should be integrated into each core capability and the coordinating structures that provide
them. Continuity capabilities increase resilience and the probability that organizations can perform
essential functions in the delivery of core capabilities that support the mission areas. FEMA is responsible
for coordinating the implementation and development, execution, and assessment of continuity
capabilities among executive departments and agencies. To support this role, FEMA develops and
promulgates directives, policy, and guidance for federal and SLTT governments, non-governmental
organizations, and private sector critical infrastructure owners and operators. Federal Continuity
Directives (FCDs) establish continuity program and planning requirements for executive departments and
agencies. This direction and guidance assist in developing capabilities for continuing the essential
functions of federal and SLTT governmental entities, as well as public/private critical infrastructure
owners, operators, and regulators enabling them.
HSGP Appendix | May 2022 Page A-28
The Federal Continuity Directives and the Continuity Resource Toolkit provide guidance and resources
for organizations. For additional information on continuity programs, guidance, and directives, visit
https://www.fema.gov/emergency-managers/national-preparedness/continuity.
Governance
In keeping with the guiding principles of governance for all FEMA preparedness programs, recipients
must coordinate activities across preparedness disciplines and levels of government, including state,
territorial, local, and tribal governments. A cohesive planning framework should incorporate FEMA
resources, as well as those from other federal and SLTT entities, the private sector, and faith-based
community organizations. Specific attention should be paid to how available preparedness funding
sources can effectively support a whole community approach to emergency preparedness and
management and the enhancement of core capabilities. To ensure this, the SAA must establish or
reestablish a unified Senior Advisory Committee. Additionally, high-risk urban areas are required to
establish UAWGs representative of the counties, cities, towns, and tribes within the high-risk urban area,
including, as appropriate, representatives of rural jurisdictions, high-population jurisdictions, and high-
threat jurisdictions.
Senior Advisory Committee (SAC)
The SAC builds upon previously established advisory bodies under the SHSP, UASI Program, Transit
Security Grant Program (TSGP), and Port Security Grant Program (PSGP). Examples of advisory bodies
that should be included on a SAC include UAWGs, SIGB, Area Maritime Security Committees
(AMSCs), Regional Transportation Security Working Groups (RTSWGs), Citizen Corps Whole
Community Councils, Disability Inclusion Working Groups, and Children’s Working Groups. The
membership of the SAC must reflect a state’s unique risk profile and the interests of the five mission areas
as outlined in the Goal. Further, the SAC must include representatives that were involved in the production
of the state’s THIRA and SPR.
SAC Composition and Scope
SAC membership shall include at least one representative from relevant stakeholders including:
• Individuals from the counties, cities, towns, and Indian tribes within the state or high-risk urban
area, including, as appropriate, representatives of rural, high-population, and high-threat
jurisdictions of UASI-funded high-risk urban areas;
• Representatives that were involved in the production of the state’s THIRA and SPR;
• State and urban area Chief Information Officers (CIOs) and Chief Information Security Officers
(CISOs);
• SWIC and SIGB members;
• Citizen Corps Whole Community Councils;
• Local or tribal government officials;
• Tribal organizations;
• Emergency response providers, including representatives of the fire service, law enforcement,
emergency medical services, and emergency managers;
• Public health officials and other appropriate medical practitioners;
• Hospitals;
• Individuals representing educational institutions, including elementary schools, middle schools,
junior high schools, high schools, community colleges, and other institutions of higher education;
• State and regional interoperable communications coordinators, as appropriate;
HSGP Appendix | May 2022 Page A-29
• State and major urban area fusion centers, as appropriate; and
• Nonprofit, faith-based, and other voluntary organizations, such as the American Red Cross.
Additionally, program representatives from the following entities should be members of the SAC (as
applicable): State Primary Care Association, State Homeland Security Advisor (HSA) (if this role is not
also the SAA), State Emergency Management Agency (EMA) Director, State Public Health Officer, State
Awardee for HHS’ Hospital Preparedness Program, State Public Safety Officer (and SAA for Justice
Assistance Grants, if different), State Coordinator for the DoD 1033 Program (also known as the Law
Enforcement Support Office [LESO] Program), State Court Official, State Emergency Medical Services
(EMS) Director, State Trauma System Manager, Statewide Interoperability Coordinator, State Citizen
Corps Whole Community Council, the State Emergency Medical Services for Children (EMSC)
Coordinator, State Education Department, State Human Services Department, State Child Welfare
Services, State Juvenile Justice Services, Urban Area POC, Senior Members of AMSCs, Senior Members
of the RTSWG, Senior Security Officials from Major Transportation Systems, and the Adjutant General.
SACs are encouraged to develop subcommittee structures, as necessary, to address the issue or region-
specific considerations. The SAC must include whole community intrastate and interstate partners as
applicable and have balanced representation among entities with operational responsibilities for
terrorism/disaster prevention, protection, mitigation, response, and recovery activities within the state, and
include representation from the stakeholder groups and disciplines identified above.
The above membership requirement does not prohibit states, high-risk urban areas, regional transit and
port entities, or other recipients of FEMA preparedness funding from retaining their existing structure
under separate programs; however, at a minimum, those bodies must support and feed into the larger
SAC. The composition, structure, and charter of the SAC should reflect this focus on building core
capabilities, instead of simply joining previously existing advisory bodies under other grant programs. For
designated high-risk urban areas, the SAA Point of Contacts (POCs) are responsible for identifying and
coordinating with the POC for the UAWG, which should be a member of the SAC. The POC’s contact
information must be provided to FEMA with the grant application. SAAs must work with existing high-
risk urban areas to ensure that information for current POCs is on file with FEMA.
Finally, FEMA recommends that organizations advocating on behalf of youth, older adults, individuals
with disabilities, individuals with limited English proficiency and others with access and functional needs,
socio-economic factors and cultural diversity be invited to participate in the SAC. Applicants must submit
the list of SAC members and the SAC charter at the time of application as an attachment in ND Grants.
SAAs will use the URT to verify compliance with SAC charter requirements.
SAC Responsibilities
The responsibilities of a SAC include:
• Integrating preparedness activities across disciplines, the private sector, nonprofit, faith-based,
and community organizations, and SLTT governments, with the goal of maximizing coordination
and reducing duplication of effort;
• Creating a cohesive planning network that builds and implements preparedness initiatives using
FEMA resources, as well as other federal, SLTT, private sector, and faith-based community
resources;
• Management of all available preparedness funding sources to ensure their effective use and to
minimize duplication of effort;
• Ensuring investments support closing capability gaps or sustaining capabilities identified in the
THIRA/SPR;
HSGP Appendix | May 2022 Page A-30
• Assist in preparation and revision of the state, regional, or local homeland security plan or the
threat and hazard identification and risk assessment, as the case may be; and
• Assist in determining effective funding priorities for SHSP grants.
SAC Charter
The governance of the SHSP and UASI programs through the SAC should be directed by a charter. All
members of the SAC should sign and date the charter showing their agreement with its content and their
representation on the Committee. Revisions to the governing charter must be sent to the recipient’s
assigned FEMA HQ Preparedness Officer. The SAC charter must at a minimum address the following:
• A detailed description of the SAC’s composition and an explanation of key governance processes,
including how the SAC is informed by the state’s and urban area’s THIRA/SPR;
• A description of the frequency at which the SAC will meet;
• How the committee will leverage existing governance bodies;
• A detailed description of how decisions on programmatic priorities funded by SHSP and UASI
are made and how those decisions will be documented and shared with its members and other
stakeholders, as appropriate; and
• A description of defined roles and responsibilities for financial decision making and meeting
administrative requirements.
To ensure ongoing coordination efforts, SAAs are encouraged to share community preparedness
information submitted in a state’s BSIR with members of the SAC. SAAs are also encouraged to share
their THIRA/SPR data with members of the SAC who are applying for other FEMA preparedness grants
to enhance their understanding of statewide capability gaps. The charter should be made available upon
request to promote transparency in decision-making related to SHSP and UASI activities.
To manage this effort and to further reinforce collaboration and coordination across the stakeholder
community, a portion of the 20% holdback of a state or territory award may be utilized by the SAA to
support the SAC and to ensure representation and active participation of SAC members. Funding may be
used for hiring and training planners, establishing and maintaining a program management structure,
identifying and managing projects, conducting research necessary to inform the planning process, and
developing plans that bridge mechanisms, documents, protocols, and procedures.
Urban Area Working Group (UAWG)
UASI program implementation and governance must include regional partners and should have balanced
representation among entities with operational responsibilities for prevention, protection, mitigation,
response, and recovery activities within the region. In some instances, high-risk urban area boundaries
cross state borders. States must ensure that the identified high-risk urban areas take an inclusive regional
approach to the development and implementation of the UASI program and involve the contiguous
jurisdictions, mutual aid partners, port authorities, rail and transit authorities, state agencies, Statewide
Interoperability Coordinators, Citizen Corps Whole Community Council(s), and campus law enforcement
in their program activities.
UAWG Composition and Scope
Pursuant to section 2003(b) of the Homeland Security Act of 2002 (codified as amended at 6 U.S.C. §
604(b)), eligible high-risk urban areas were determined based on an analysis of relative risk of the 100
most populous Metropolitan Statistical Areas (MSAs), as defined by the Office of Management and
Budget (OMB). MSAs are used by FEMA to determine eligibility for participation in the program.
HSGP Appendix | May 2022 Page A-31
Geographical areas queried do not equate to minimum mandated membership representation of an urban
area, nor does this guarantee funding for geographical areas queried. UAWGs are not required to expand
or contract existing urban area participation to conform to MSA composition. Detailed information on
MSAs is publicly available from the United States Census Bureau at https://www.census.gov/programs-
surveys/metro-micro.html.
An SAA must confirm a specific POC with the designated high-risk urban area. The SAA POC is
responsible for identifying and coordinating with the POC for the UAWG. This information must be
provided to FEMA with the grant application. SAAs must work with existing high-risk urban areas to
ensure that information for current POCs is on file with FEMA.
Membership in the UAWG must provide either direct or indirect representation for all relevant
jurisdictions and response disciplines (including law enforcement, fire service, EMS, hospitals, public
health, and emergency management) that comprise the defined high-risk urban area. It must also be
inclusive of local Whole Community Citizen Corps Council and tribal representatives. The UAWG
should also include at least one representative from each of the following significant stakeholders:
• Local or tribal government officials
• CIO and CISO
• Emergency response providers, which shall include representatives of the fire service, law
enforcement, emergency medical services, and emergency managers
• Public health officials and other appropriate medical practitioners, including Health Care
Coalitions (HCCs)
• Individuals representing educational institutions, including elementary schools, middle schools,
junior high schools, high schools, community colleges, and other institutions of higher education
• State and regional interoperable communications coordinators, and state and major urban area
fusion centers, as appropriate
In addition to representatives from the local jurisdictions and tribes within the state or high-risk urban
area, the UAWG should include officials responsible for the administration of Centers for Disease
Control and Prevention’s (CDC) and the HHS Assistant Secretary for Preparedness and Response’s
(ASPR) cooperative agreements. Finally, it must be inclusive of members advocating on behalf of youth,
older adults, individuals with disabilities, individuals with limited English proficiency and others with
access and functional needs, socio-economic factors, and cultural diversity.
High-risk urban areas will use the URT to verify UAWG structure and membership. The list of UAWG
members must also be submitted at the time of application as an attachment in ND Grants. High-risk
urban areas must notify the SAA and the FEMA Headquarters Preparedness Officer of any updates to the
UAWG structure or membership after the application is submitted.
UAWG Responsibilities
UAWGs must ensure that applications for funding under the UASI program support closing capability
gaps or sustaining capabilities identified in the high-risk urban area’s THIRA/SPR. The UAWG should
support state efforts to develop the SPR, particularly as it relates to UASI-funded activities. The UAWG,
in coordination with the SAA POC, must develop a methodology for allocating funding available through
the UASI program. The UAWG must reach consensus on all UASI funding allocations. If consensus
cannot be reached within the 45-day period allotted for the state to obligate funds to subrecipients, the
SAA must make the allocation determination. The SAA must provide written documentation verifying
the consensus of the UAWG or the failure to achieve otherwise on the allocation of funds and submit it to
FEMA immediately after the 45-day period allotted for the state to obligate funds to subrecipients. Any
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UASI funds retained by the state must be used in direct support of the high-risk urban area. States must
provide documentation to the UAWG, and FEMA upon request, demonstrating how any UASI funds
retained by a state are directly supporting the high-risk urban area.
UAWG Charter
In keeping with sound project management practices, the UAWG must ensure that its approach to critical
issues such as membership, governance structure, voting rights, grant management and administration
responsibilities, and funding allocation methodologies are formalized in a working group charter, or
another form of standard operating procedure related to the UASI program governance. The charter must
also outline how decisions made in UAWG meetings will be documented and shared with UAWG
members. The UAWG charter must be submitted at the time of application as an attachment in ND Grants
and must be on file with FEMA prior to drawing down UASI funding. It also must be available to all
UAWG members to promote transparency in decision making related to the UASI program.
Supplemental SHSP and UASI Guidance
Collaboration
Collaboration with Other Federal Preparedness Programs
FEMA strongly encourages states, high-risk urban areas, tribes, and territories to understand other federal
preparedness programs in their jurisdictions and to work with them in a collaborative manner to leverage
all available resources and avoid duplicative activities. For example, HHS has two robust preparedness
programs—CDC’s Public Health Emergency Preparedness (PHEP) cooperative agreement and ASPR’s
Hospital Preparedness Program (HPP) cooperative agreement—that focus on preparedness capabilities.
CDC’s 15 public health preparedness capabilities and ASPR’s 4 healthcare preparedness capabilities
serve as operational components for many of the core capabilities, and collaboration with the PHEP
directors and HPP coordinators can build capacity around shared interests and investments that fall in the
scope of these HHS cooperative agreements and the HSGP.
States and high-risk urban areas should coordinate among the entire scope of federal partners, national
initiatives, and grant programs to identify opportunities to leverage resources when implementing their
preparedness programs. These may include but are not limited to: Medical Reserve Corps; Emergency
Medical Services for Children grants; ASPR HPP; CDC PHEP; CDC Cities Readiness Initiative;
Strategic National Stockpile Programs; EMS; DOJ grants; the Department of Defense 1033 Program (also
known as the LESO Program); and the Resilience Directorate/Office of Infrastructure Protection’s (OIP)
Regional Resilience Assessment Program (RRAP). However, coordination is not limited to grant funding.
It also includes leveraging assessments such a Transportation Security Agency’s (TSA) Baseline
Assessment for Security Enhancement (BASE), reporting from the Intelligence Community, risk
information such as USCG’s Maritime Security Risk Analysis Model (MSRAM), and USBP Sector
Analysis.
Each SHSP- and UASI-funded investment that addresses biological risk, patient care, or health systems
preparedness should be implemented in a coordinated manner with other federal programs that support
biological and public health incident preparedness such as those administered by HHS ASPR, CDC, and
DOT’s National Highway Traffic Safety Administration (NHTSA).
Collaboration with Health Care Coalitions (HCCs)
HCCs are regional entities comprised of health care, public health, emergency management, and
emergency medical services organizations that plan and respond together, leverage resources, and address
HSGP Appendix | May 2022 Page A-33
challenges in health care delivery brought on by public health and medical incidents. Given that many of
the risks being mitigated include the potential for a range of mass casualties, including those across the
chemical, biological, radiological, nuclear, explosive (CBRNE) spectrum, planning efforts should include
the participation of HCCs and should take into account the elements and capabilities articulated in the
2017-2022 Health Care Preparedness and Response Capabilities
(https://www.phe.gov/Preparedness/planning/hpp/reports/Documents/2017-2022-healthcare-pr-
capablities.pdf ).
Collaboration with Nonprofit Organizations
SHSP and UASI recipients are encouraged to work with the nonprofit community to address terrorism
and all-hazards prevention concerns, seek input on the needs of the nonprofit sector, and support the goals
of their investments.
Collaboration with Tribes
FEMA strongly encourages states, high-risk urban areas, and territories to work with tribal nations in
overall initiatives, such as whole community preparedness and emergency management planning.
Whole Community Preparedness
SHSP and UASI recipients should engage with the whole community to advance community and
individual preparedness and to work as a nation to build and sustain resilience. Recipients should consider
the three goals of the 2022-2026 FEMA Strategic Plan in their program design and delivery, specifically
Strategic Goal 1.3: Achieve equitable outcomes for those we serve, and Strategic Goal 3: Promoting and
sustaining a prepared nation. Recipients should integrate program design and delivery practices that
ensure representation and services for under-represented diverse populations that may be more impacted
by disasters including children, seniors, individuals with disabilities or access and functional needs,
individuals with diverse culture and language use, individuals with lower economic capacity, and other
underserved populations. Individual preparedness must be coordinated by an integrated body of
government and nongovernmental representatives as well, including but not limited to, elected officials,
the private sector (especially privately owned critical infrastructure), private nonprofits, nongovernmental
organizations (including faith-based, community-based, and voluntary organizations), advocacy groups
for under-represented diverse populations that may be more impacted by disasters including children,
seniors, individuals with disabilities or access and functional needs, individuals with diverse culture and
language use, individuals with lower economic capacity, and other underserved populations.
FEMA has programming designed to increase the resilience of individual Americans and communities.
Please email Prepare@fema.dhs.gov to contact one of the Agency’s subject matter experts to receive
guidance and assistance. The following tools, trainings, and products may be ordered directly, free of
charge, from FEMA’s warehouse at https://orders.gpo.gov/icpd/ICPD.aspx; many of them might be
allowable costs, but recipients and subrecipients should ensure that these activities can also help
build target capabilities for preventing, preparing for, protecting against, and responding to acts of
terrorism.
• Community Emergency Response Team (CERT) programs, which educate volunteers about
disaster preparedness for the hazards that may impact their area and train them in basic disaster
response skills, such as fire safety, light search and rescue, team organization, and disaster
medical operations. CERT offers a consistent, nationwide approach to volunteer training and
organization that professional responders can rely on during disaster situations, allowing them to
focus on more complex tasks.
HSGP Appendix | May 2022 Page A-34
• Financial Resilience: FEMA partners with philanthropic and nonprofit organizations to increase
the financial resilience of the public in advance of disasters, including acts of terrorism. Activities
include helping the public to organize finances and increasing the understanding of what FEMA
assistance can provide. Partnerships with local financial wellness organizations such as credit
unions, financial counselors, community banks, and others that reach a variety of audiences are
encouraged. The Emergency Financial First Aid Kit (EFFAK) provides individuals, families, and
businesses the ability to organize critical financial, medical, and household information. It
includes a checklist of important documents and forms to compile your relevant information.
• Building Capacity with Community Based Organizations: Community-Based Organizations
serve as a critical safety net for Americans disproportionately impacted by disasters, including
acts of terrorism. Allowable activities include Whole Community exercises, trainings, and
activities focused on staff preparedness; information sharing with clients and government; and
continuity of essential functions in the event of an emergency. In 2019, FEMA launched the
Organizations Preparing for Emergency Needs Training (OPEN). OPEN includes both a web-
based, self-guided training, and a downloadable instructor kit that will guide participants on how
to identify risks, locate resources, and take preparedness actions. When Community-Based
Organizations, such as food pantries, daycares, and nonprofits, are unable to sustain operations
during an emergency incident, individuals who rely on them are exponentially impacted. Because
of their importance in keeping the community going, OPEN is designed to empower these
organizations to better prepare for incidents. Community-Based Organizations include but are not
limited to food banks, food pantries, homeless shelters, school readiness and after school centers,
adult day care centers, job training centers, legal assistance centers, and cultural centers.
• Preparedness Actions: FEMA curates validated guidance for decision-making (protective
actions) for the public in order to increase survival rates and improve disaster recovery, including
from acts of terrorism. Recipients may order, free of charge, hazard information sheets on 17
different types of threats and hazards, the “12 Ways to Prepare Postcard,” guidance on how to
create an emergency communications plan for a family, and a breadth of depth of other material
at https://orders.gpo.gov/icpd/ICPD.aspx.
• Youth Preparedness Resources are available on www.ready.gov/kids. Bolstering youth
preparedness across the nation is a priority for FEMA as the Agency works with state, local,
tribal, and territorial partners to create a culture of preparedness in the United States. Information
on youth-centric educational curricula, games, planning materials, and other relevant resources
can be found at www.ready.gov/kids.
The following are examples of youth preparedness activities that grantees are encouraged to
undertake as allowable costs:
o Reach out to a local school board or elementary school to encourage the adoption of the
Student Tools for Emergency Planning (STEP) curriculum. STEP is a classroom-based
emergency preparedness curriculum for 4th- and 5th-graders in an easy, ready-to-teach
format. Students will learn about disasters, emergencies, and hazards, and how to create a
disaster supply kit and family emergency communication plan. An overview of the STEP
program along with the instructor guide and student activity book is available at
https://www.ready.gov/student-tools-emergency-planning-step; and
o Sponsor the creation of a Teen CERT in your jurisdiction. The CERT Program is a
national program of volunteers trained in disaster preparedness and emergency response.
Volunteers come from all ages and all walks of life, including teenagers. Additional
information, including a step-by-step guide on how to start a Teen CERT, is available at
https://www.ready.gov/teen-cert.
The following tools are available to order from FEMA’s warehouse free of charge:
HSGP Appendix | May 2022 Page A-35
o “Prepare with Pedro” is a joint product of FEMA and the American Red Cross. The
“Prepare with Pedro: Disaster Preparedness Activity Book” is designed to teach young
children and their families about how to stay safe during disasters and emergencies. The
book follows Pedro around the United States and offers safety advice through
crosswords, coloring pages, matching games, and more. Additional information,
including an ordering form, is available at https://www.ready.gov/prepare-pedro; and
o The Ready 2 Help card game is a fun way for kids to learn how to respond to
emergencies by working with friends and using skills that will help in a real emergency.
Ready 2 Help teaches five simple steps to stay safe and make a difference until help
arrives:
• Stay Safe;
• Stay Calm;
• Get Help;
• Give Info; and
• Give Care.
Ready 2 Help is designed for children ages 8 and up. Additional information, including
an ordering form, is available at https://www.ready.gov/ready-2-help.
Supplemental OPSG Program Guidance
OPSG supports enhanced cooperation and coordination among CBP, USBP, and federal and SLTT law
enforcement agencies to improve overall border security. OPSG provides funding to support joint efforts
to secure the United States’ borders along routes of ingress/egress to and from international borders to
include travel corridors in states bordering Mexico and Canada, as well as states and territories with
international water borders. OPSG also further enhances the sharing of threat information and intelligence
between federal, state, local, tribal, and territorial law enforcement agencies through the development and
sustainment of a capable workforce of analysts that have the necessary experience and training, access to
open source, unclassified and classified information, products, data, suspicious activity reporting,
tips/leads, and online/social media-based threats, as well as necessary services and technology to facilitate
analytic capabilities and collaboration.
SLTT law enforcement agencies will utilize their own law enforcement authorities to support the CBP
and USBP border security mission and will not receive any additional authority as a result of participation
in the grant. An OPSG award does not provide any additional authority to SLTT law enforcement
agencies. More specifically, SLTT law enforcement agencies are not empowered through OPSG to
enforce immigration authorities under Title 8 of the U.S. Code (i.e., the Immigration and Nationality Act).
SLTT law enforcement agencies are expected utilize their own jurisdictional authority in support of
enhanced border security unless some other agreement applies. SLTT law enforcement agencies are
further expected to operate within the bounds of all applicable laws, to include federal laws, state statutes,
and local laws, policies, and procedures.
OPSG is intended to support border states and territories of the United States in accomplishing the
following objectives:
• Increase intelligence and operational capabilities to prevent, protect against, and respond to
border security issues;
• Increase coordination and collaboration among federal and SLTT law enforcement agencies;
• Continue the distinct capability enhancements required for border security and border protection;
HSGP Appendix | May 2022 Page A-36
• Provide intelligence-based operations through USBP Sector Level experts to ensure safety and
operational oversight of federal and SLTT law enforcement agencies participating in OPSG
operational activities;
• Support a request to any Governor to activate, deploy, or redeploy specialized National Guard
Units/Packages and/or elements of state law enforcement to increase or augment
specialized/technical law enforcement elements operational activities;
• Continue to increase operational, material, and technological readiness of SLTT law enforcement
agencies;
• Enhance the sharing of threat information and intelligence between federal and SLTT law
enforcement agencies; and
• Develop and sustain a capable workforce of analysts that have the necessary experience and
training, as well as access to open source, unclassified, and/or classified information, products,
data, suspicious activity reporting, tips/leads, and online/social media-based threats, and the
necessary services and technology to facilitate these analytic activities.
OPSG funds must be used to provide an enhanced law enforcement presence and to increase operational
and intelligence capabilities of federal and SLTT law enforcement, promoting a layered, coordinated
approach to law enforcement within border states and territories of the United States.
• Federal and SLTT OPSG Integrated Planning Team (IPT). Federal and SLTT partners must
establish and maintain a formalized OPSG IPT with representation from all participating law
enforcement agencies, co-chaired by representatives from USBP, the SAA, and participating law
enforcement agencies’ OPSG program representatives.
• No fewer than two IPT meetings must take place during every funding year:
o Prior to submitting the Concept of Operations (application)
o Prior to submitting the Campaign Plan
• OPSG funds may be used for travel and per diem in support of the IPTs and OPSG strategic
planning events as long as the costs are otherwise compliant with other program and regulatory
requirements.
Coordination Requirements
All operational plans should be crafted in cooperation and coordination among federal and SLTT
partners. Consideration will be given to applications that are coordinated across multiple jurisdictions. All
applicants must coordinate with the USBP Sector Headquarters with geographic responsibility for the
applicant’s location in developing and submitting an Operations Order with an embedded budget to the
SAA. OPSG funds must be used to provide increased operational capabilities to SLTT partners in support
of enhanced border security through:
• Enhanced Law Enforcement Presence;
• Enhanced Situational Awareness; and
• Enhanced Intelligence Collection and Distribution.
After awards are announced, prospective recipients will re-scope the draft Operations Order and resubmit
it as a final Operations Order with an embedded budget based on actual dollar amounts awarded. The
appropriate Sector Headquarters will approve final Operations Orders and forward those orders to
Headquarters, Office of Border Patrol, Washington, DC, before funding is released. Recipients may not
begin operations, obligate, or expend any funds until FEMA and USBP Headquarters have approved the
final Operations Order and the embedded budget and removed any existing special conditions and/or
restrictions.
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Transportation Costs and Costs Related to the Provision of Acute Medical Care
Please see IB 438 for information on transportation costs and costs related to the provision of acute
medical care under an OPSG award.
OPSG Operations Order Template and Instructions
Operations Order Template Instructions
To access the OPSG Operations Order Template:
• Find the Homeland Security Grant Program posting via the search function on Grants.gov;
• Select the Related Documents tab on the posting; and
• Click on the OPSG Operations Order Template and fill out all sections of the template.
Executive Summary Overview
Operations Order Executive Summary
Operations Order Executive Summary must:
• Identify the organization name, point of contact, committees, and other structures accountable for
implementing OPSG in the jurisdiction (typically this will be a program lead or manager
overseeing operations and individuals assigned to that agency); and
• Describe how federal and SLTT law enforcement agencies will work together to establish and
enhance coordination and collaboration on border security issues.
Budget Requirements Overview
Operations Order Detailed Annual Budget must:
• Explain how costs and expenses were estimated; and
• Provide a narrative justification for costs and expenses. Supporting tables describing cost and
expense elements (e.g., equipment, fuel, vehicle maintenance costs) may be included.
Submission Requirements
Operations Orders must meet the following submission requirements:
• Must be submitted as an Adobe PDF document;
• All documents submitted must use the unique identifier created by the OPSG data management
system from the original associated operation order; and
• Applicable OPSG sector representatives must coordinate with the SAA and OPSG participants to
submit an accurate inventory of all specified OPSG purchased property with each Operations
Order/FRAGO.
Due to the competitive nature of this program, separate attachments will neither be accepted nor
reviewed.
OPSG Operational Guidance
This section provides operational guidance to OPSG applicants on the development of a concept of
operations and campaign planning, the tactical operation period, and reporting procedures. This guidance
also delineates specific roles and responsibilities, expectations for operations, and performance measures.
HSGP Appendix | May 2022 Page A-38
Successful execution of these objectives will promote situational awareness among participating agencies
and ensure a rapid, fluid response to emerging border-security conditions.
OPSG uses an integrated approach to address transnational criminal activity. Federal and SLTT partners
are required to establish and maintain an OPSG IPT with representation from all participating law
enforcement agencies, co-chaired by representatives from USBP, the SAA, and participating local law
enforcement agencies’ OPSG program representatives. Each operational order will address specific
threats, gaps, and vulnerabilities identified by the USBP. All requests in the operational plan will be
reviewed and approved by the corresponding sector's Chief Patrol Agent or his/her designee for border
security value. USBP will provide routine monitoring and technical expertise to each participating
agency. The content of each operational plan, to include the requested items will be reviewed for border-
security value and approved by the corresponding sector’s Chief Patrol Agent or his/her designee.
All operational plans should be crafted in cooperation and coordination with federal and SLTT partners to
meet the needs of the USBP Sector. Consideration will be given to applications that are coordinated
across multiple jurisdictions. All applicants must coordinate with the CBP/USBP Sector Headquarters
with geographic responsibility for the applicant’s location in developing and submitting an Operations
Order with an embedded budget to the SAA. Operations are to be crafted so that resources are allocated to
one or more of the supportable categories:
1) Law Enforcement Presence;
2) Situational Awareness; and/or
3) Intelligence Collection, Analysis, and Distribution.
Law Enforcement Presence includes activities and costs associated to having an SLTT partner provide a
law enforcement patrol presence in an area designated by the USBP Sector in support of border security
efforts. Situational Awareness includes technology to provide current and immediately relevant
information about currently active border security threats. Intelligence Collection and Distribution
includes both technology and manpower related to the gathering and analysis of intelligence with a nexus
to border security.
The terms of an OPSG award do not extend to an SLTT partner any authority to enforce additional laws,
statues, or regulations beyond their own authorities; SLTT partners are not empowered through OPSG to
enforce immigration authorities under Title 8 of the U.S. Code (i.e., the INA). Participation in the grant
does not grant participants the power to operate outside of their own jurisdictional boundaries.
Concept of Operations and Campaign Planning
Post-Allocation Announcement/Pre-Award
The overarching operational cycle involves three stages: 1) application; and 2) concept of operations to
formulate a Campaign Plan, which are all developed by the IPT. All Operations Orders: Concept of
Operations (CONOPS), Operation Orders (OO) or Campaign Plans and FRAGOs shall be submitted
through the CBP Stonegarden Data Management System. All OPSG grant Application packages shall be
submitted to the SAA for entry into Grants.gov.
Application: Please refer to the current fiscal year’s HSGP NOFO and relevant information in this
Manual.
Campaign Plan: After awards are announced, participants will create and submit an operations order that
forms a campaign plan and captures the initial, generalized-budgetary intent to their IPT.
HSGP Appendix | May 2022 Page A-39
The campaign plan should articulate the participant agency’s long-term border security objectives and
goals designed to mitigate border-security risk.
Funds should be obligated as needed to target specific threats or vulnerabilities and ensure that OPSG
usage is commensurate to the unique risk of each border region. This may require several short-term
operations that combine to form an ongoing operational cycle, ensuring that USBP commanders and
SLTT agency partners reserve the flexibility to respond to the ever-changing elements of border security.
The operations plan also will articulate the budgetary intent of how funds are to be used throughout the
performance period. The operations plan will project planned expenditures in the following categories:
overtime, equipment, travel, maintenance, fuel, and administrative funds. The subrecipient can initiate the
procurement of equipment as well as state how much the county intends to use for M&A while keeping
funds for overtime or residual equipment funds available for use as needed. If the subrecipient intends to
spend more than 50% of its award on overtime over the course of the performance period, a PRICE Act
waiver request must be submitted in accordance with the policy initially outlined in IB 379: Guidance to
State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding. The
operations plan will meet both the SAA expectations to obligate the funds within 45 days of the award
announcement and the demands of the grant’s operational intent. Sector approved campaign plans must
be submitted to USBP Headquarters no later than four months after the official awards
announcement has been made.
Investment Modifications - Changes in Scope or Objective: Changes in scope or objective of the
award – including those resulting from intended actions by the recipient or subrecipients – require
FEMA’s prior written approval, in accordance with 2 C.F.R. §§ 200.308(c)(1), 200.407.
In the event that changes must be made to the original operational plan, such as additional funding
requests or other changes to the original scope or objectives, a FRAGO must be submitted in HSIN to
obtain FEMA’s prior written approval of such changes in accordance with 2 C.F.R. § 200.308(c)(1).
These modifications will be annotated in the annex section of the FRAGO.
Operational Execution
In the event that changes or additional funding requests to the original operational order must be made, a
FRAGO will be created. These modifications will be annotated in the annex section of the FRAGO.
Operational discipline is necessary for the success of OPSG. Deliberate, adaptive, integrated, and
intelligence-driven planning is critical to conducting targeted enforcement operations consistent with the
objectives of the OPSG. By participating in the OPSG, the state, local, tribal, and territorial agencies
agree to conduct operations designed to reduce border-security risk.
Operations are composed of six critical elements: 1) a pre-planning meeting with the IPT; 2) specified
beginning and ending dates; 3) the integration of intelligence and border security; 4) use of targeted
enforcement techniques; 5) clearly stated objectives; and 6) an after-action meeting. These operations
require deliberate on-going planning to ensure command, staff, and unit activities synchronize to current
and future operations. The cyclical nature of the process will ensure OPSG activities align with the
fluctuating border-security threats and vulnerabilities. The IPT should leverage information provided by
the fusion center, Border Intelligence Centers, or other local intelligence center, when possible, and
establish a common operational vision.
The USBP Sector’s Chief Patrol Agent, or his/her designee, will ensure that the information or
intelligence has a clear nexus to border security. Intelligence will be shared and vetted for border security
value, driving the focus of operations. Once intelligence-driven targets are identified, the IPT will decide
on operational objectives that reflect the intended impact of operations. The objectives should outline how
HSGP Appendix | May 2022 Page A-40
the operation will deter, deny, degrade, or dismantle the operational capacity of the targeted transnational
criminal organizations.
Each operational period will begin on a predetermined date and end on a predetermined date, but the dates
may be subject to change commensurate with emerging security conditions. The starting date of the
operational period should be established to allow sufficient time for the order to be submitted and
approved by the corresponding USBP Sector and in concurrence with its SAA and USBP Headquarters.
The USBP Sectors will upload copies of operations order in the corresponding folder in the CBP
Stonegarden Data Management System.
Reporting Procedures
Participation in OPSG requires accurate, consistent, and timely reporting of how funds are used, and how
the state, local and tribal agencies’ operations have impacted border security through the mitigation of
threat or vulnerability and the overall reduction of risk. Reporting will focus on monitoring program
performance; determining the level of integration and information sharing; and developing best practices
for future operations. To ensure consistent reporting each state, local, and tribal agency will identify a
single point of contact to represent their agency as a member of the IPT and to coordinate the submission
of reports or execute other aspects of the grant.
The Daily Activity Report (DAR), which can be found by selecting the link for the current fiscal year
HSGP NOFO on FEMA’s preparedness grants page (https://www.fema.gov/homeland-security-grant-
program) to be used to submit the ongoing results and outputs from OPSG operations conducted. The
information and statistics included in the DAR will be delineated by agency (friendly forces). The DAR
must be submitted to the USBP sector or the participating agency’s OPSG coordinator within 48 hours
of the conclusion of each OPSG shift. Subrecipients and Sectors are responsible to ensure that DARs are
submitted in the proper format and in a timely manner. DARs will be submitted using the CBP
Stonegarden Data Management System. Friendly Forces receiving funding through a subrecipient will
submit DARs within 48 hours. Border Patrol Sectors and OPSG subrecipients will implement internal
protocols to ensure operational data from subrecipients and friendly force DARs are properly collected
following the established guidelines.
In addition to the ongoing reporting of outputs, subrecipient participants will be required to submit AARs
to USBP sectors within 10 days of closing the operational POP for that funding year. The AAR should
carefully articulate outcomes and outputs as well as how the results of the operation compare with the
objectives identified during the pre-planning meeting. Failure to submit the AAR in a timely manner may
prevent the approval of future operations requests. All AARs and other OPSG reporting requirements will
be submitted through the CBP Stonegarden Data Management System. Sectors are responsible for
submitting AARs into Border Patrol Enforcement Tracking System (BPETS) as applicable.
Operational Roles and Responsibilities
To achieve unity of effort, it is essential that each participant know the roles and responsibilities within
the IPT. The USBP sector’s Chief Patrol Agent, or his/her designee, will:
• Coordinate and chair the area IPT’s meetings;
• Coordinate with all interested and eligible SLTT agencies in the sector’s area of operation during
the open period of the OPSG application process by:
o Assisting applicants in completing the operations planning portion of the application,
which is like the Operations Order used by the USBP;
HSGP Appendix | May 2022 Page A-41
o Forwarding the approved operation portion of the application to CBP/USBP
Headquarters as well as to the SAA to complete the application process set by FEMA;
and
o Detailing what operational support the USBP Sector anticipates for specific periods and
matching the capabilities of partners to fill those gaps.
• Following the announcement of grant awards, coordinate and chair a meeting with SLTT
agencies that received OPSG awards to develop an individualized campaign plan. This includes:
o Working with SLTT agencies, along with other federal law enforcement agencies to
determine the dates, focus, and needs of each operational period, ensuring that each
operation has a nexus to border security;
o Receiving the first periodic operations order from the SLTT agencies and ensuring that
the operation is conducted as outlined in the Campaign Planning section;
o Monitoring and supporting the Operational Cycle throughout the performance period
o Ensuring the DAR and the AAR are submitted by state, local, and tribal agencies in the
proper format and within the established timeframes;
o Providing instruction, when possible, to state, local, and tribal agencies regarding
techniques, methods, and trends used by transnational criminal organizations in the area;
o Providing a single point of contact to participants as a subject-matter expert in OPSG that
can coordinate, collect, and report operational activities within the established reporting
procedures;
o Providing verification that operations are conducted;
o Documenting and conducting random, on-site operational verification of OPSG patrols
by subrecipients and friendly forces;
o Verifying that subrecipients are performing OPSG enforcement duties in accordance with
the applicable grant, statute, and regulatory guidance and instructions; and
o Ensuring that grant funds are appropriately expended to meet sector border enforcement
operational requirements and assist in enhancing subrecipient/friendly force capabilities
to provide for enhanced enforcement presence, operational integration, and intelligence
sharing in border communities.
The state, local or tribal agency lead, or their designee, will:
• Coordinate with the SAA on all grant management matters including but not limited to the
development and review of operations orders, expenditure of funds, allowable costs, reporting
requirements;
• Upon receiving a grant award, coordinate and meet as a member of the IPT to develop an
individualized campaign plan that covers the length of the grant performance period;
• Work within the IPT to develop an initial Operational Cycle and determine the duration of the
first operational period based on the tactical needs specific to the area;
• Submit all operations orders for review and submit the operations order to the Border Patrol and
ensure the operation meets the six criteria established in the Operations Section:
o Conduct operations on an as-needed basis throughout the length of the grant performance
period;
o Integrate law enforcement partners from contiguous counties and towns into their tactical
operations to expand the layer of security beyond existing areas;
o Ensure all required reports, including reports from friendly forces, are submitted to the
Border Patrol and the SAA, when applicable, in the proper format and within established
timeframes;
o Ensure applicable OPSG-derived data is shared with the designated fusion center in the
state or high-risk urban areas;
HSGP Appendix | May 2022 Page A-42
o Ensure applicable intelligence is shared with the designated fusion center in the state
and/or high-risk urban areas;
o Request instruction and information from the SAA, when applicable, and/or USBP and
other federal law enforcement agencies regarding techniques, methods, and trends used
by transnational criminal organizations in the area;
o Provide the SAA and USBP a single point of contact that maintains subject-matter
expertise in OPSG who can coordinate, collect, and report operational activities within
the established reporting procedures; and
o Assist as required with the coordination, management, and operational aspects of the
grant.
The SAA will:
• Actively engage in the IPT meetings;
• Work in direct coordination and communication with the local or tribal agency lead on all grant
management matters;
• Review all operations orders created by the local or tribal agency;
• Acts as the fiduciary agent for the program and provide expertise in state policy and regulations;
• Enter into a subaward agreement to disburse the allocated funding awarded through FEMA;
• Generate biannual reports to FEMA capturing the subrecipients’ obligations and expenditures of
funds;
• Determine if the grant’s performance period requires additional refinement over the federally
established 36-month period;
• Conduct audits of the program to ensure that the subrecipients are following program guidance;
and
• Assist as required with the coordination, management, and operational aspects of the grant.
Definitions (OPSG only)
Area of Interest: A specific area, areas, or facilities known to be used by transnational criminal
organizations in furtherance of their criminal activity.
Border-security related crime: Any action or enterprise that constitutes an offense which is punishable by
law:
• That results in a favorable environment for criminal enterprise network, transnational criminal, or
terrorist organizations; the smuggling/trafficking of humans, contraband, narcotics, or weapons of
mass destruction across or in proximity to the U.S. border or;
• That has a direct nexus to illicit cross-border activity; and
• For which prosecution would serve established border security goals as outlined by the CBP for a
whole of community approach.
Campaign Plan: The first Operational Order based on the CONOP aimed at accomplishing a strategic or
operational objective within a given time and space.
Concept of Operations (CONOP): A written statement that clearly and concisely expresses what the
State, local, or tribal commander intends to accomplish and how it will be done using available resources
(and funding). It is also the operational equivalent of the OPSG grant application.
Fragmentary Order (FRAGO): A fragmentary order is a modification of the approved campaign plan,
reflecting changes to the scope or objective pursuant to 2 C.F.R. § 200.308(c)(1). After an operation order
has been approved, any changes to a campaign plan will be submitted via HSIN as a FRAGO for FEMA’s
HSGP Appendix | May 2022 Page A-43
approval. Subsequent FRAGOs are permissible, subject to FEMA’s prior written approval, consistent
with the requirements of 2 C.F.R. §§ 200.308, 200.407.
Friendly Forces: Local law enforcement entities with whom OPSG subrecipients provide funding to
support border security operations.
Integrated Planning Team (IPT): Group that coordinates on all aspects of OPSG application, planning,
and de-briefings.
Operational Cycle: A deliberate on-going cycle of command, staff, and unit activities intended to
synchronize current and future operations (driven by current intelligence and short-term goals that
support the campaign).
Operational Discipline: The organized manner in which an organization plans, coordinates, and executes
the OPSG mission with common objectives toward a particular outcome.
Operation/Operational Order (OO): A formal description of the action to be taken to accomplish or
satisfy a CONOP, Campaign Plan, or FRAGO. The OO includes a detailed description of actions to be
taken and required logistical needs to execute an operation.
Opioid Receptor Antagonists: Any medically approved drug or medical substance that can be utilized by
first responder personnel in an emergency situation that is designed to counteract the effects of an opioid
overdose.
Performance Measure: A numerical expression that quantitatively conveys how well the organization is
doing against an associated performance goal, objective, or standard.
Risk: Potential for an adverse outcome assessed as a function of threats, vulnerabilities, and consequences
associated with an incident, event, or occurrence.
Targeted Enforcement: The leveraging of all available assets against a specific action, area, individual, or
organization and using those deemed most appropriate to mitigate risk.
Target of Interest: A specific person, group of persons, or conveyance known to be part of, or used by
transnational criminal organizations to advance their criminal activity.
Threat: Information expressing intent to conduct illegal activity often derived from intelligence sources,
the overall context, a specific event or series of events, or observation of suspicious activity.
Tier: Tier refers to the geographical location of a municipality, county, or tribe with respect to the United
States national border, i.e., Tier 1 is a county located on the border; a Tier 2 county is a county contiguous
to a Tier 1 county; and a. Tier 3 is a county not located on the physical border but is a contiguous to a Tier
2 county.
Unity of Effort: Coordination and cooperation among all organizational elements, even though they may
not be part of the same command structure, to achieve success.
Vulnerability: The protective measures in place are less than the protective measures needed to mitigate
risk.
HSGP Appendix | May 2022 Page A-44
HSGP Supplemental Material
FEMA collaborates with various subject-matter experts and acknowledges the value and expertise these
Federal partner agencies provide to help shape the development and implementation of the HSGP. This
continued partnership and collaboration helps provide recipients with the greatest number of resources
required to effectively manage and implement funds as well as promotes transparency. Therefore, FEMA
is providing hyperlinks to information on various subjects and policies that are relevant to the mission and
intent of the FEMA and its preparedness grant programs.
Chemical, Biological, Radiological, and Nuclear (CBRN) Detection
The Countering Weapons of Mass Destruction (CWMD) Office is a support component within DHS
established in December 2017 to counter attempts by terrorists or other threat actors to carry out an attack
against the United States or its interests using a weapon of mass destruction. The CWMD Office provides
guidance to improve national coordination on CBRN issues and works with federal and SLTT agencies to
ensure operators have better access to current data and subject matter expertise they need. CWMD offers
THIRA Technical Assistance for CBRN threats to provide guidance to SLTT partners seeking to build or
sustain CBRN detection and response capabilities. For more information or assistance, please contact
CWMD-THIRA@hq.dhs.gov.
National Information Exchange Model (NIEM)
NIEM is a common vocabulary that enables efficient information exchange across diverse public and
private organizations. NIEM can save time and money by providing consistent, reusable data terms and
definitions and repeatable processes. To support information sharing, all recipients of grants for projects
implementing information exchange capabilities are required to use NIEM and to adhere to the NIEM
conformance rules. Go to https://niem.gov/ for guidance on how to utilize FEMA award funding for
information sharing, exchange, and interoperability activities.
The NIEM Emergency Management domain supports emergency-related services (including preparing
first responders and responding to disasters), information sharing, and activities such as homeland
security and resource and communications management. The NIEM Emergency Management domain has
an inclusive governance structure that includes federal, state, local, industry, and, where necessary,
international partnerships. The NIEM Emergency Management domain is committed to community
support via technical assistance and NIEM training. For more information on the NIEM Emergency
Management domain, to request training or technical assistance or to just get involved, go to
https://niem.gov/EM.
Integrated Public Alert and Warning System (IPAWS)
The current IPAWS Supplemental Guidance on Public Alert and Warning provides guidance on eligible
public alert and warning activities and equipment standards for prospective SLTT recipients. The intent of
this document is to promote consistency in policy across federal grant programs and to ensure
compatibility among federally funded projects. For more information on the IPAWS, go to
https://www.fema.gov/informational-materials.
Homeland Security Information Network (HSIN)
HSIN is a user-driven, web-based, information sharing platform that connects all homeland security
professionals including the DHS and its federal, state, local, tribal, territorial, international, and private
sector partners across all homeland security mission areas. HSIN is used to support daily operations,
events, exercises, natural disasters, and incidents. To support user mission needs, HSIN provides three
sets of services for secure information sharing. The first service provides a shared place for communities
to securely collaborate on homeland security issues and includes core functions such as a web
HSGP Appendix | May 2022 Page A-45
conferencing and instant messaging tools with white boarding, video, and chat services for real-time
communication and situational awareness. The second set provides secure dissemination and sharing
capabilities for homeland security alerts, reports, and products. The third set allows users to access and
query a variety of shared data and services from all homeland security mission areas and trusted federal
partners. Preparedness grant funds may be used to support planning, training and development costs
associated with developing and managing, mission critical, HSIN communities of interest and sites. Learn
more about HSIN at http://www.dhs.gov/hsin-hsgp-guidance.
SLTT Cybersecurity Engagement Program
CISA is responsible for enhancing the security, resilience, and reliability of the Nation’s cyber and
communications infrastructure. CISA works to prevent or minimize disruptions to critical information
infrastructure to protect the public, the economy, and government services. CISA leads efforts to protect
the Federal “.gov” domain of civilian government networks and to collaborate with the private sector—
the “.com” domain—to increase the security of critical networks.
The DHS SLTT Cybersecurity Engagement Program within CISA was established to help non-federal
public stakeholders and associations manage cyber risk. The program provides appointed and elected
SLTT government officials with cybersecurity risk briefings, information on available resources, and
partnership opportunities to help protect their citizens online. Through these and related activities, the
program coordinates DHS’s cybersecurity efforts with its SLTT partners to enhance and protect their
cyber interests. More information on all of the CISA resources available to support SLTT governments is
available at https://us-cert.cisa.gov/resources.
Framework for Improving Critical Infrastructure Cybersecurity
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in
implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the
“Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework
gathers existing international standards and practices to help organizations understand, communicate, and
manage their cyber risks. For organizations that do not know where to start with developing a
cybersecurity program, the Framework provides initial guidance. For organizations with more advanced
practices, the Framework offers a way to improve their programs, such as better communication with
their leadership and suppliers about management of cyber risks.
CISA’s Critical Infrastructure Cyber Community C³ Voluntary Program also provides resources to critical
infrastructure owners and operators to assist in adoption of the Framework and managing cyber risks.
Additional information on the Critical Infrastructure Cyber Community C³ Voluntary Program can be
found at http://www.cisa.gov/ccubedvp.
DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in
protecting U.S.-based public and private entities and combines key elements of capabilities under the
“Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the
Cybersecurity Framework. Specifically, ECS offers intrusion prevention and analysis services that help
U.S.-based companies and SLTT governments defend their computer systems against unauthorized
access, exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat
indicators from sensitive and classified Government Furnished Information (GFI). DHS then shares those
indicators with accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to
block certain types of malicious traffic from entering a company’s networks. Groups interested in
subscribing to ECS must contract directly with a CSP in order to receive services. Please visit
http://www.cisa.gov/enhanced-cybersecurity-services for a current list of ECS CSP points of contact.
HSGP Appendix | May 2022 Page A-46
Regional Resiliency Assessment Program (RRAP)
The RRAP is a cooperative assessment of specific critical infrastructure within a designated geographic
area and a regional analysis of the surrounding infrastructure that address a range of infrastructure
resilience issues that could have regionally and nationally significant consequences. These voluntary,
non-regulatory RRAP projects are led by the Infrastructure Security Division and are selected each year
by DHS with input and guidance from federal, state, and local partners. For additional information on the
RRAP, visit https://www.cisa.gov/regional-resiliency-assessment-programassessment-program.
Law Enforcement Support Office (LESO), or 1033 Program
The LESO facilitates a law enforcement support program, which originated from the National Defense
Authorization Act of Fiscal Year 1997. This law allows the transfer of excess Department of Defense
property that might otherwise be destroyed by law enforcement agencies across the United States and its
territories.
No equipment is purchased for distribution. All items were excess that had been turned in by military
units or had been held as part of reserve stocks until no longer needed. Requisitions cover the gamut of
items used by America’s military ― clothing and office supplies, tools, and rescue equipment, vehicles,
small arms, and more. There is no fee for the equipment itself, however, the law enforcement agencies are
responsible for the shipping costs.
For additional information on the LESO, please visit
http://www.dla.mil/DispositionServices/Offers/Reutilization/LawEnforcement.aspx.
Supplemental Emergency Communications Guidance
Lessons learned from recent major disasters, unplanned events, and full-scale exercises have identified a
need for greater coordination of emergency communications among senior elected officials, emergency
management agencies, and first responders at all levels of government. Federal responders arriving on the
scene of a domestic incident are not always able to communicate with SLTT response agencies, as well as
key government officials. State and local first responders sometimes experience similar problems,
particularly when the incident requires a multi-agency, regional response effort or when primary
communications capabilities fail. This lack of operability and interoperability between federal and SLTT
agencies―further complicated by problems with communications survivability and resilience―has
hindered the ability to share critical information, which can compromise the unity-of-effort required for
an effective incident response.
Departments and agencies at all levels of government have identified a need for improvement in a number
of high-priority areas, including Governance, Planning, Training and Exercises, Operational
Coordination, and Technology. In addition, communications resilience and continuity should be viewed
as a critical component within each of these areas. These priorities are explained in detail in Section 2 of
the SAFECOM Guidance. By addressing these priorities, which are reflective of proven best practices,
emergency communications can be significantly improved at all levels of government. The end goal is to
ensure operable, interoperable, and resilient communications that maintain a continuous flow of critical
information, under all conditions, among multi-jurisdictional and multi-disciplinary emergency
responders, command posts, agencies, critical infrastructure sectors, and government officials for the
duration of an emergency response operation, and in accordance with NIMS and the National Emergency
Communications Plan, which describes goals and objectives for improving emergency communications
nationwide.
HSGP Appendix | May 2022 Page A-47
To help meet this goal, the SAFECOM Guidance outlines requirements for grant applications, including
alignment to national, regional, and state communications plans (e.g., NECP, Statewide Communication
Interoperability Plan (SCIP), Tactical Interoperability Communications Plan (TICP), FEMA Regional
Emergency Communications Plan (RECP)), project coordination, and technical standards for emergency
communications technologies. SCIPs define the current and future direction for interoperable and
emergency communications within a state or territory, while TICPs are designed to allow urban areas,
counties, regions, states/territories, tribes, or federal departments/agencies to document interoperable
communications governance structures, technology assets, and usage policies and procedures. In addition,
FEMA’s formal planning process has produced 10 RECPs and their associated state and/or
tribal/territorial annexes that identify emergency communications capability shortfalls and potential
resource requirements. Grant recipients are encouraged to leverage these planning resources as a source
of input and reference for all emergency communications grant applications and investment justifications.
In addition, FEMA formally recognizes several statewide emergency communications governance bodies
(e.g., SWIC, SIGB, Statewide Interoperability Executive Committee (SIEC), FirstNet State Single Point
of Contact (SPOC)), and strongly encourages grant recipients to closely coordinate with these entities
when developing an emergency communications investment to ensure projects support the state or
territory’s strategy to improve their communications capabilities with the goal of achieving fully operable,
interoperable, and resilient communications. In addition, grant applicants should work with public and
private entities, and across jurisdictions and disciplines, to demonstrate engagement with the Whole
Community in accordance with Presidential Policy Directive-8 (PPD-8).
For regional, cross-border initiatives, FEMA requires applicants to coordinate projects with national level
emergency communications coordination bodies, such as the National Council of Statewide
Interoperability Coordinators (NCSWIC) and the Regional Emergency Communications Coordination
Working Groups (RECCWGs). The NCSWIC promotes and coordinates state-level activities designed to
ensure the highest level of public safety communications across the nation. RECCWGs are
congressionally mandated planning and coordination bodies located in each FEMA Region and provide a
collaborative forum to assess and address the survivability, sustainability, operability, and interoperability
of emergency communications systems at all levels of government. Grant-funded investments that are
coordinated with these bodies will help ensure that federally funded emergency communications
investments are interoperable and support national policies.
Resilient Communications Guidance
Nothing better demonstrates a modern nation than its ability to effectively communicate. The risk
imposed by the reliance on communication systems by government and the private sector can be reduced
by understanding dependencies, analyzing effects, and taking action. Entities planning to use HSGP
funding for communications investments are encouraged to work with state emergency management
agencies, SWICs, SIGBs, and appropriate stakeholders at the regional, state, local, territorial, and tribal
levels to:
• Establish robust, resilient, reliable, and interoperable communications capabilities. Account for
the mission impact of communication system disruptions in your planning;
• Ensure mission-related communications (voice, video, data, and network security requirements)
are adequately planned for and understood. It is important to maintain current documentation of
your communication systems architecture and perform regular audits. Your ability to continue
operations is dependent on the availability of and access to communications systems with
sufficient resiliency, redundancy, and accessibility to perform essential functions and provide
critical services during a disruption;
HSGP Appendix | May 2022 Page A-48
• Ensure critical communication systems connectivity among key government leadership, internal
elements, other supporting organizations, and the public under all conditions. As such,
organizations should ensure current copies of vital records, including electronic files and
software, are backed-up and maintained off-site;
• Ensure all communications systems/networks are traced from end to end to identify all Single
Points of Failure (SPF). In doing so, grantees should work with communication service providers
to add redundancy at key critical infrastructure facilities as needed;
• Ensure key communication systems resiliency through:
o Ensuring availability of backup systems;
o Ensuring diversity of network element components and routing;
o Ensuring geographic separation of primary and alternate transmission media;
o Ensuring availability of back-up power sources;
o Ensuring availability and access to systems that are not dependent on commercial
infrastructure;
o Maintain spares for designated critical communication systems; and
o Work with commercial suppliers to remediate communication Single Points of Failure.
• All communications system owners are encouraged to address the following issues:
o Integrate communications needs into continuity planning efforts by incorporating
mitigation options to ensure uninterrupted communications support;
o Establish a cybersecurity plan that includes continuity of a communications component
such as Radio Frequency (RF)-based communications that do not rely on public
infrastructure;
o Maintain communications capabilities to ensure their readiness when needed;
o Frequently train and exercise personnel required to operate communications capabilities
o Test and exercise communications capabilities; and
o Consider Electromagnetic Pulse (EMP) protective measures for communications systems
where practical.
DHS/FEMA Communications Support Services
CISA and FEMA offer a variety of technical assistance and other support services to assist state and local
entities in their efforts to comply with the above requirements, including the SAFECOM Guidance, with
the goal of ensuring interoperable and resilient emergency communications. A summary of DHS/FEMA
support services is provided below. Grant recipients are encouraged to refer to the respective websites for
additional information.
CISA Support:
CISA assists agencies through a myriad of services, including direct TA and training provided at no cost
to the jurisdiction. The TA offerings include (but are not limited to):
• Coordinated statewide governance (e.g., State Mapping Tool, Interoperable Communications
Reference Guides);
• Comprehensive emergency communications planning (e.g., SCIPs, TICPs, and Field Operations
Guides);
• Next Generation 911 planning and implementation;
• Data operability and interoperability;
• Alerts and warnings;
• Broadband deployment;
• Cybersecurity education and awareness; and
• Communications Unit (COMU) planning and procedures.
HSGP Appendix | May 2022 Page A-49
Information on these services is available at https://www.cisa.gov/safecom/ictapscip-resources and
https://www.cisa.gov/interoperable-communications-technical-assistance-program.
FEMA Disaster Emergency Communications Division (DEC) Support:
The DEC, within FEMA Headquarters’ Response Directorate, has developed State Communications
Annexes for all 56 states and territories. DEC provides technical assistance, coordinated through the
FEMA Region’s Regional Emergency Communications Coordinator (RECC) in scheduling with the
states and territories for major updates to the Annexes. Major updates are scheduled on a 3 to 5-year
cycle. FEMA DEC supports the major update with a team of communications and emergency
management specialists that facilitate a process of interaction with state representatives. This process is
coordinated through the SWIC or state designated representative. All documentation is the responsibility
of the FEMA support team and validated through state interaction.
Minor yearly updates to the State Annexes are accomplished through the RECCWG process. FEMA DEC
support staff, working in coordination with the region-specific RECC, incorporate pertinent update
information provided by state and local representatives. Additionally, operational information identified
through exercises and incident response activities is a source of update data. The FEMA RECC, with the
support of the DEC team, is responsible for maintaining the State Annexes ― changes and modifications
to the Annexes are validated with the state through RECC coordination with the SWIC or designated state
representative.
FEMA National Preparedness Directorate (NPD) Support:
NPD provides training, exercises, and technical assistance to SLTT stakeholders that support operational
and emergency communications. Descriptions and resources specific to operational communication are
available on FEMA’s website (https://www.fema.gov/core-capability-development-sheets) within the
Response Mission Area and include the following information to support jurisdictions:
• Description of the operational communications core capability;
• Training for building and sustaining operational communication with specific course titles:
o Trainings can also be found at https://www.firstrespondertraining.gov/.
• Example capability targets to complete a THIRA:
o Help in developing targets can be found at www.preptoolkit.fema.gov/urt or requested at
FEMA-SPR@fema.dhs.gov.
• Resource types that support operational communications:
o Additional resource types and position qualifications can be found at
https://www.fema.gov/preparedness-checklists-toolkits.
• Tools to validate capabilities through exercises:
o Technical assistance and support from subject matter experts can be requested through
www.fema.gov/national-exercise-program.
FEMA National Continuity Programs (NCP) Support:
NCP’s support services focus on holistic continuity planning, of which communications continuity is an
important component. Currently, continuity communications training and technical assistance is limited to
the FEMA National Radio System (FNARS) and IPAWS and is delivered either on an ad hoc basis at the
request of the state entity, through a FEMA Region, or via a requirement for terms of use. Entities
interested in NCP support services should contact FEMA-CGC@fema.dhs.gov or consult NCP’s
Continuity Resources Toolkit webpage at https://www.fema.gov/emergency-managers/national-
preparedness/continuity/toolkit.
THSGP Appendix | May 2022 Page B-1
Program Appendix B:
Tribal Homeland Security Grant Program (THSGP)
As a reminder, while this appendix contains THSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the THSGP. Please be sure to read the main content of this
Manual in addition to the program-specific appendices.
Alignment of THSGP to the National Preparedness System
The THSGP plays an important role in the implementation of the National Preparedness Goal by
supporting the building, sustainment, and delivery of the core capabilities. The core capabilities are
essential for the execution of critical tasks for each of the five mission areas outlined in the Goal.
Delivering core capabilities requires the combined effort of the whole community, rather than the
exclusive effort of any single organization or level of government. THSGP allowable costs support efforts
to build and sustain core capabilities across the prevention, protection, mitigation, response, and recovery
mission areas described in the Goal.
Particular emphasis in THSGP will be placed on capabilities that address the greatest risks to the security
and resilience of tribal communities and the United States and that provide a clear nexus to preventing
acts of terrorism. Funding will support deployable assets that can be utilized through automatic assistance
and mutual aid agreements. THSGP supports investments that improve the ability of jurisdictions
nationwide to:
• Prevent a threatened or an actual act of terrorism;
• Protect our citizens, residents, visitors, and assets against the greatest threats and hazards;
• Mitigate the loss of life and property by lessening the impact of future disasters;
• Respond quickly to save lives, protect property and the environment, and meet basic human needs
in the aftermath of a catastrophic incident; and/or
• Recover through a focus on the timely restoration, strengthening, and revitalization of
infrastructure, housing, and a sustainable economy, as well as the health, social, cultural, historic,
and environmental fabric of communities affected by a catastrophic incident.
To support building, sustaining, and delivering these core capabilities, recipients will use the components
of the National Preparedness System, which include Identifying and Assessing Risk, Estimating
Capability Requirements, Building and Sustaining Capabilities, Planning to Deliver Capabilities,
Validating Capabilities, and Reviewing and Updating. Additional information on the National
Preparedness System is available at: http://www.fema.gov/national-preparedness-system.
FEMA requires recipients to prioritize grant funding to demonstrate how investments support identified
national priorities and closing capability gaps or sustaining capabilities identified in the Threat and
Hazard Identification and Risk Assessment (THIRA)/Stakeholder Preparedness Review (SPR) process. In
addition to capability gaps they have identified at their level, recipients should consider areas where
national capability gaps are the largest, which are outlined in the most recent National Preparedness
Report. They include cybersecurity, economic recovery, housing, infrastructure systems, natural and
cultural resources, and supply chain integrity and security. Addressing these areas for improvement will
enhance preparedness nationwide. Minimum funding amounts are not prescribed by the Department for
THSGP Appendix | May 2022 Page B-2
these priorities; however, recipients are expected to support state, local, regional, and national efforts in
achieving the desired outcomes of these priorities.
Reporting on the Implementation of the National Preparedness System
By December 31, 2022, THSGP recipients are required to complete a THIRA/SPR that addresses all 32
core capabilities and is compliant with the Comprehensive Preparedness Guide (CPG) 201, Third Edition.
THSGP recipients must complete every step of the THIRA/SPR for the following eight core capabilities:
Cybersecurity; Infrastructure Systems; Mass Care Services; Mass Search and Rescue Operations; On-
scene Security, Protection, and Law Enforcement; Operational Communications; Operational
Coordination; and Public Information and Warning. For the remaining 24 core capabilities, THSGP
recipients are only required to indicate planning, organization, equipment, training, and exercise gaps in
functional areas related to those capabilities. THSGP recipients may optionally complete additional
portions of the THIRA/SPR for these 24 core capabilities.
THSGP recipients are required to respond to a series of planning-related questions as part of the
THIRA/SPR. THSGP recipients are required to submit a THIRA every three years to establish a
consistent baseline for assessment. While the THIRA is only required every three years, THSGP
recipients are required to submit an SPR annually. For additional guidance on the THIRA/SPR, please
refer to the Comprehensive Preparedness Guide (CPG) 201, Third Edition. Recipients must align THSGP
grant investments in building and sustaining capabilities with closing capability gaps and/or sustaining
capabilities they identified in their THIRA and SPR.
Reporting Requirements
• THSGP recipients must submit their THIRA/SPR through the Unified Reporting Tool (URT) on
Prep Toolkit no later than December 31 for the years they have open THSGP grant awards. If a
recipient has completed closeout for their THSGP grant award period of performance, they do not
have to submit any more THIRA/SPR updates as the requirement does not apply to closed
awards.
• Please contact FEMA-SPR@fema.dhs.gov if you have questions.
• In each THSGP recipient’s Biannual Strategy and Implementation Report (BSIR), as part of
programmatic monitoring, recipients will be required to describe how investments support closing
capability gaps or sustaining capabilities identified in the THIRA/SPR. THSGP recipients will, on
a project-by-project basis, check one of the following:
o Building a capability with THSGP funding; or
o Sustaining a capability with THSGP funding.
National Incident Management System (NIMS) Implementation
Recipients receiving THSGP funding are required to implement the National Incident Management
System (NIMS). NIMS guides all levels of government, nongovernmental organizations (NGO), and the
private sector to work together to prevent, protect against, mitigate, respond to, and recover from
incidents. NIMS provides stakeholders across the whole community with the shared vocabulary, systems,
and processes to successfully deliver the capabilities described in the National Preparedness Goal.
THSGP recipients must utilize standardized resource management concepts such as typing, credentialing,
and inventorying resources that facilitates the effective identification, dispatch, deployment, tracking and
recovery of their resources.
The NIMS Implementation Objectives for Local, State, Tribal, and Territorial Jurisdictions clarifies the
NIMS implementation requirements in FEMA preparedness grant Notices of Funding Opportunities
THSGP Appendix | May 2022 Page B-3
(NOFOs). As recipients and subrecipients of federal preparedness (non-disaster) grant awards,
jurisdictions and organizations must achieve, or be actively working to achieve, all of the NIMS
Implementation Objectives. The objectives can be found on the NIMS webpage at
https://www.fema.gov/emergency-managers/nims/implementation-training.
Reporting Requirements
Recipients report in the applicable secondary NIMS assessment portion of the URT as part of their
THIRA/SPR submission, as outlined in the THSGP NOFO.
Planning to Deliver Capabilities
Recipients shall develop and maintain a jurisdiction-wide, all threats and hazards Emergency Operations
Plans (EOPs) consistent with CPG 101 Version 2.0 (CPG 101 v2). Recipients must submit an EOP once
during the period of performance.
Reporting Requirements
Recipients report EOP compliance with Developing and Maintaining Emergency Operations Plans by
completing the secondary CPG 101 v2 assessment portion of the URT as part of their THIRA/SPR
submission, as outlined in the THSGP NOFO.
Validating Capabilities
All recipients will develop and maintain a progressive exercise program consistent with Homeland
Security Exercise and Evaluation Program (HSEEP) guidance in support of the National Exercise
Program (NEP). The NEP serves as the principal exercise mechanism for examining national
preparedness and measuring readiness. The NEP is a two-year cycle of exercises across the nation that
validates capabilities in all preparedness mission areas. The two-year NEP cycle is guided by Principals’
Strategic Priorities, established by the National Security Council, and informed by preparedness data from
jurisdictions across the Nation.
To develop and maintain a progressive exercise program consistent with HSEEP and in support of the
NEP, recipients should engage senior leaders and other whole community stakeholders to identify
preparedness priorities. These priorities should be informed by various factors, including jurisdiction-
specific threats and hazards (i.e., the THIRA); areas for improvement identified by real-world events and
exercises; external requirements such as state or national preparedness reports, homeland security policy,
and industry reports; and accreditation standards, regulations, or legislative requirements. Recipients
should document these priorities and use them to deploy a schedule of preparedness events in a multi-year
Integrated Preparedness Plan (IPP). Information related to IPPs and Integrated Preparedness Planning
Workshops (IPPWs) can be found on the HSEEP website at https://www.fema.gov/emergency-
managers/national-preparedness/exercises/hseep and https://preptoolkit.fema.gov/.
The NEP provides exercise sponsors the opportunity to receive exercise design and delivery assistance,
tools and resources, enhanced coordination, and the ability to directly influence and inform policy and
preparedness programs. If you have any questions or would like to request assistance through the NEP,
please visit the NEP website at: https://www.fema.gov/national-exercise-program or reach out to the NEP
directly at NEP@fema.dhs.gov.
Reporting Requirements
• Recipients must have a current multi-year IPP that identifies preparedness priorities and
activities. The current multi-year IPP must be submitted to hseep@fema.dhs.gov before January
31 of each year:
THSGP Appendix | May 2022 Page B-4
o Recipients are encouraged to enter their exercise information into the Preparedness
Toolkit at https://preptoolkit.fema.gov/.
• Recipients must submit After-Action Report (AAR)/Improvement Plans (IPs) to
hseep@fema.dhs.gov and indicate which fiscal year’s funds were used (if applicable);
• Submission of AAR/IPs must occur within 90 days after completion of the single exercise or
progressive series:
o Recipients are encouraged to submit AAR/IPs reflecting tabletop exercises that validate
critical plans or those reflecting large-scale functional or full-scale exercises that took
place at the state, territorial, tribal, or UASI level. Recipients are discouraged from
submitting AAR/IPs specific to local jurisdictions that reflect drills;
o If a recipient endures a significant real-world incident during the calendar year that
delays or prevents conduct of a grant-funded exercise, they can submit the AAR from
that event in place of the exercise AAR. Jurisdictions submitting real world AARs should
include an explanation with the AAR submission to hseep@fema.dhs.gov; and
o Recipients can access a sample AAR/IP template at
https://preptoolkit.fema.gov/web/hseep-resources/improvement-planning.
THSGP Funding Guidelines
Recipients and subrecipients must comply with all applicable requirements of the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards located at 2 C.F.R. Part 200.
In administering a THSGP grant award, recipients must comply with the following general requirements:
THSGP Priorities
See the annual THSGP NOFO.
Allowable Costs
Management and Administration (M&A)
M&A activities are those defined as directly relating to the management and administration of THSGP
funds, such as financial management and monitoring. Recipients may use up to 5% of the amount of the
award for M&A, and where applicable, subrecipients may use up to 5% for M&A of the amount they
receive. Reasonable costs of grant management training are also allowable.
Indirect (Facilities and Administrative [F&A]) Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
THSGP Appendix | May 2022 Page B-5
Allowable Direct Costs
The following pages outline global allowable costs guidance specifically applicable to THSGP.
Allowable activities made in support of the national priorities, as well as other capability-enhancing
projects must fall into the categories of planning, organization, equipment, training, or exercises
(POETE). Additional detail about each of these allowable expense categories, as well as sections on
additional activities including explicitly unallowable costs is provided. In general, recipients should
consult their FEMA Preparedness Officer prior to implementing any investment to ensure that it clearly
meets the allowable expense criteria established by the guidance.
Recipients are encouraged to use grant funds for evaluating grant-funded project effectiveness and return
on investment aligned to the relevant POETE element, and FEMA encourages grant recipients to provide
the results of that analysis to FEMA.
Planning
Planning efforts can include prioritizing needs; conducting risk and resilience assessments on increasingly
connected cyber and physical systems, on which security depends, using the Infrastructure Resilience
Planning Framework and related CISA resources; updating preparedness strategies; and allocating
resources across stakeholder groups (e.g., law enforcement, fire, emergency medical services, health care
systems, public health, behavioral health, public works, rural water associations, agriculture, information
technology, emergency communications, and the general public, including people with disabilities) and
levels of government. Planning provides a methodical way to engage the whole community in thinking
through the life cycle of potential crises, determining required capabilities, and establishing a framework
for roles and responsibilities. Planning must include participation from all stakeholders in the community
who are able to contribute critical perspectives and may have a role in executing the plan. Planning should
be flexible enough to address incidents of varying types and magnitudes.
Planning activities should focus on the prevention, protection, mitigation, response, and recovery mission
areas outlined in the Goal. All jurisdictions are encouraged to work with Citizen Corps Whole
Community Councils, nongovernmental entities, and the general public in planning activities. Whole
community planning should integrate program design and delivery practices that ensure representation
and services for under-represented diverse populations that may be more impacted by disasters including
children, seniors, individuals with disabilities or access and functional needs, individuals with diverse
culture and language use, individuals with lower economic capacity and other underserved populations.
Recipients must use the CPG 101 v2, Third Edition in order to develop robust and effective plans.
For additional planning and resource information, please see:
http://www.fema.gov/pdf/about/divisions/npd/CPG_101_V2.pdf
http://www.cisa.gov/idr-program (Infrastructure Resilience Planning Framework)
http://www.ready.gov/citizen-corps
http://www.fema.gov/community-emergency-response-teams
www.ready.gov/kids
http://www.fema.gov/media-library/assets/documents/94775
https://www.fema.gov/sites/default/files/2020-06/national_disaster_recovery_framework_2nd.pdf
Additionally, THSGP funds may be used for planning activities related to 911 call capabilities, alert and
warning capabilities, and implementation of the REAL ID Act (Pub. L. No. 109-13).
THSGP Appendix | May 2022 Page B-6
Continuity Capability
FEMA is responsible for developing, managing, and promulgating national continuity planning, guidance,
training, and exercise programs for the whole community. To support this role, FEMA provides direction
and guidance to assist in developing capabilities for continuing federal and state, local, tribal, and
territorial (SLTT) government jurisdictions and private sector organizations' essential functions across a
broad spectrum of emergencies.
Presidential Policy Directive 40, Federal Continuity Directive (FCD) 1, FCD 2, and Continuity Guidance
Circular (CGC) outline continuity requirements for agencies and organizations and provide guidance,
methodology, and checklists. For additional information on continuity programs, guidance, and
directives, visit the Continuity Resource Toolkit at https://www.fema.gov/emergency-managers/national-
preparedness/continuity/toolkit.
Organization
Recipients may use grant funds for organization activities:
• Organizational activities may include, paying salaries and benefits for personnel, including
individuals employed to serve as qualified intelligence analysts. Personnel hiring, overtime, and
backfill expenses are permitted under this grant only to the extent that such expenses are for the
allowable activities within the scope of the grant.
• Other organization activities may include implementing standardized resource management
concepts such as typing, inventorying, organizing, and tracking to facilitate the dispatch,
deployment, and recovery of resources before, during, and after an incident.
Additionally, migrating online services to the “.gov” internet domain is an allowable expense.
Equipment
The 21 allowable prevention, protection, mitigation, response, and recovery equipment categories and
equipment standards for THSGP are listed on the web-based version of the Authorized Equipment List
(AEL). Unless otherwise stated, equipment must meet all mandatory regulatory and DHS-adopted
standards to be eligible for purchase using these funds. In addition, recipients and subrecipients, as
applicable, agencies will be responsible for obtaining and maintaining all necessary certifications and
licenses for the requested equipment. Recipients may purchase equipment not listed on the AEL, but only
if they first seek and obtain prior approval from FEMA.
Grant funds must comply with Information Bulletin (IB) 426, Guidance to Recipients and Subrecipients
of FEMA Preparedness Grants Regarding the Implementation of Executive Order 13809 Restoring State,
Tribal, and Local Law Enforcement’s Access to Life-Saving Equipment and Resources, dated November
1, 2017, and may not be used for the purchase of the following unallowable equipment: firearms,
ammunition, grenade launchers, bayonets, or weaponized aircraft, vessels, or vehicles of any kind with
weapons installed. Recipients should analyze the costs and benefits of purchasing versus leasing
equipment, especially high-cost items, and those subject to rapid technical advances. Large equipment
purchases must be identified and explained. For more information regarding property management
standards for equipment, please reference 2 C.F.R. Part 200, including 2 C.F.R. §§ 200.310, 200.313, and
200.316. Also see 2 C.F.R. §§ 200.216, 200.471, and FEMA Policy #405-143-1, Prohibitions on
Expending FEMA Award Funds for Covered Telecommunications Equipment or Services, issued May 10,
2022. In addition, recipients that are using THSGP funds to support emergency communications
equipment activities must comply with the SAFECOM Guidance on Emergency Communications Grants,
including provisions on technical standards that ensure and enhance interoperable communications. This
SAFECOM Guidance can be found at https://www.cisa.gov/safecom/funding.
THSGP Appendix | May 2022 Page B-7
Additionally, THSGP funds may be used for equipment purchases related to 911 call capabilities, alert
and warning capabilities, and implementation of the REAL ID Act (Pub. L. No. 109-13).
Requirements for Small Unmanned Aircraft System
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and also include a description of the policies and procedures in place to safeguard individuals’
privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or otherwise use the
sUAS equipment. SUAS policies are not required at the time of application but must be received and
approved by FEMA prior to obligating THSGP funds. All grant-funded procurements must be executed in
a manner compliant with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. For recipients
that use THSGP funds for sUAS, FEMA advises that there is a general privacy concern related to the use
of this equipment if the data the devices collect is transmitted to servers not under the control of the
operator. It has been reported that some manufacturers of sUAS encrypt data and send that data to servers
outside the United States. The U.S. Department of Homeland Security’s Privacy Office suggests the
recipient fully explore data transmission and storage issues with vendors to reduce the possibility of data
breaches.
Additionally, the Joint Explanatory Statement (JES) accompanying the FY 2022 DHS Appropriations Act
further requires recipients to certify they have reviewed the Industry Alert on Chinese Manufactured
Unmanned Aircraft Systems, and completed a risk assessment that considers the proposed use of foreign-
made sUAS to ascertain potential risks (e.g., privacy, data breaches, cybersecurity, etc.) related to foreign-
made versus domestic sUAS.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA was alerted of an advisory guidance document issued by DHS, the Department of
Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.
The purpose of the advisory guidance document is to help non-federal public and private entities better
understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate
threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
representations of the systems’ legality or functionality. Please also see the DHS press release on this
topic for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-
technology-detect-and-mitigate-unmanned-aircraft.
Training and Exercises
Tribes are strongly encouraged to use THSGP funds to develop or maintain a homeland security training
program. Allowable training-related costs under the THSGP include the establishment, support, conduct,
and attendance of training specifically identified under the THSGP or in conjunction with emergency
preparedness training by other federal agencies (e.g., the Department of Health and Human Services or
THSGP Appendix | May 2022 Page B-8
the Department of Transportation). Training conducted using THSGP funds should address a performance
gap identified through an assessment or contribute to building a capability that will be evaluated through a
formal exercise. Exercises should be used to provide the opportunity to demonstrate and validate skills
learned in training, as well as to identify training gaps. Any training or training gaps evaluated though a
formal exercise, including those for vulnerable populations including children, the elderly, pregnant
women, and individuals with disabilities or access and functional needs should be identified in an
AAR/IP.
All training and exercises conducted with THSGP funds should support the development and testing of
the jurisdiction’s Emergency Operations Plan (EOP), consistent with the priorities in the National
Preparedness System. Recipients are encouraged to use existing training rather than developing new
courses. When developing new courses, recipients are encouraged to apply the Analysis, Design,
Development, Implement, and Evaluate (ADDIE) model of instruction design, available with additional
training information at https://www.firstrespondertraining.gov.
FEMA supports and encourages the coordination of all emergency preparedness training towards the
achievement of the Goal. To this end, FEMA supports the establishment of a Tribal Training Point of
Contact (TTPOC). The role of the TTPOC is to coordinate the tribes’ training needs and activities with
FEMA and FEMA’s federal training partners and holds the same authority and roles that state training
points of contact serve within SAAs nationwide. FEMA will coordinate with Tribal Training Officers
(TTOs) as it relates to FEMA training when notified by recipients.
Per FEMA Grant Programs Directorate IB 432, Review and Approval Requirements for Training Courses
Funded Through Preparedness Grants, issued on July 19, 2018, states, territories, tribal entities, and
high-risk urban areas are no longer required to request approval from FEMA for personnel to attend non-
DHS/FEMA training as long as the training is coordinated with and approved by the state, territory, tribal,
or high-risk urban area TPOC and falls within the FEMA mission scope and the jurisdiction’s EOP. For
additional information on review and approval requirements for training courses funded with
preparedness grants, please refer to the following policy: https://www.fema.gov/sites/default/files/2020-
09/fema_gpd-review-approval-requirements-training-policy_09-10-13.pdf.
DHS/FEMA Provided Training and Education
FEMA offers tuition-free training and education programs and courses through several providers
including the Center for Domestic Preparedness, the Emergency Management Institute, and the National
Training and Education Division’s Training Partner Program (TPP). TPP includes the Center for
Homeland Defense and Security, National Domestic Preparedness Consortium, Rural Domestic
Preparedness Consortium, and training partners through the Continuing Training Grants program.
FEMA’s National Preparedness Course Catalog
This online searchable catalog features a wide range of course topics in multiple delivery modes to meet
FEMA’s mission scope as well as the increasing training needs of federal, state, local, territorial, and
tribal audiences. The catalog can be accessed at http://www.firstrespondertraining.gov.
Training Not Provided by DHS/FEMA
These trainings include courses that are either state sponsored or federal sponsored (non-DHS/FEMA),
coordinated and approved by the SAA or their designated TPOC, and fall within the FEMA mission
scope to prepare SLTT personnel to prevent, protect against, mitigate, respond to, and recover from acts
of terrorism or catastrophic events.
THSGP Appendix | May 2022 Page B-9
• State Sponsored Courses. These courses are developed for and/or delivered by institutions or
organizations other than federal entities or FEMA and are sponsored by the SAA or their
designated TPOC.
• Joint Training and Exercises with the Public and Private Sectors. These courses are
sponsored and coordinated by private sector entities to enhance public-private partnerships for
training personnel to prevent, protect against, mitigate, respond to, and recover from acts of
terrorism or catastrophic events. In addition, states, territories, tribes, and high-risk urban areas
are encouraged to incorporate the private sector in government-sponsored training and exercises.
Additional information on both FEMA provided training and other federal and state training can be found
at http://www.firstrespondertraining.gov.
Training Information Reporting System (“Web-Forms”)
Web-Forms is an electronic data management system built to assist SAAs, designated TPOCs, and federal
agencies with submitting non-National Training and Education Division provided training courses for
inclusion in the State/Federal-Sponsored Course Catalog through electronic forms. The information
collected is used in a two-step review process to ensure the training programs adhere to the intent of the
HSGP guidance and the course content is structurally sound and current. As these programs may be
delivered nationwide, it is vital to ensure each training program's viability and relevance to the Homeland
Security mission. Reporting training activities through Web-Forms is not required under FY 2022
THSGP. However, the system remains available and can be accessed through the Web-Forms section of
the FEMA National Preparedness Course Catalog to support recipients in their own tracking of training
deliveries.
Exercises
For additional information on conducting exercises under THSGP, please refer to the earlier section in
this appendix titled “Validating Capabilities” on page B-3.
Personnel Activities
Personnel hiring, overtime, and backfill expenses are permitted under this grant in order to perform
allowable THSGP planning, training, exercise, and equipment activities.
Not more than 50% of total THSGP funds may be used for personnel activities as directed by the
Homeland Security Act of 2002, as amended by the Personnel Reimbursement for Intelligence
Cooperation and Enhancement (PRICE) of Homeland Security Act (Pub. L. No. 110-412) (6 U.S.C.
§609(b)(2)(A)). This 50% cap may be waived, however, per 6 U.S.C. § 609(b)(2)(B). For further details,
THSGP recipients should refer to IB 421b, or contact their FEMA HQ Preparedness Officer. THSGP
funds may not be used to support the hiring of any personnel for the purposes of fulfilling traditional
public safety duties or to supplant traditional public safety positions and responsibilities.
Construction and Renovation
Construction projects are only permitted where they will assist the recipient to achieve target capabilities
related to preventing, preparing for, protecting against, or responding to acts of terrorism, including
through the alteration or remodeling of existing buildings for the purpose of making them secure against
acts of terrorism. THSGP funding may not be used for construction and renovation projects without prior
written approval from FEMA. All recipients of THSGP funds must request and receive approval from
FEMA before any THSGP funds are used for any construction or renovation. Additionally, recipients are
required to submit an SF-424C Form containing budget detail citing the construction project costs and an
SF-424D Form for standard assurances for the construction project. The total cost of any construction or
THSGP Appendix | May 2022 Page B-10
renovation paid for using THSGP funds may not exceed the greater amount of $1 million or 15% of the
THSGP award.
All construction and renovation projects require Environmental Planning and Historic Preservation (EHP)
review. Recipients and subrecipients are encouraged to have completed as many steps as possible for a
successful EHP review in support of their proposal for funding (e.g., coordination with their State
Historic Preservation Office to identify potential historic preservation issues and to discuss the potential
for project effects, compliance with all state and local EHP laws and requirements). Projects for which the
recipient believes an EA may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision
01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ
Preparedness Officer within six months of the award and completed EHP review materials must be
submitted no later than 12 months before the end of the period of performance. EHP policy guidance and
the EHP Screening Form, can be found online at: https://www.fema.gov/media-
library/assets/documents/90195. EHP review materials should be sent to gpdehpinfo@fema.dhs.gov.
THSGP recipients using funds for construction projects must comply with the Davis-Bacon Act (codified
as amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. §
5196(j)(9), which cross-references Davis-Bacon). Grant recipients must ensure that their contractors or
subcontractors for construction projects pay workers no less than the prevailing wages for laborers and
mechanics employed on projects of a character similar to the contract work in the civil subdivision of the
state in which the work is to be performed. Additional information regarding compliance with the Davis-
Bacon Act, including Department of Labor (DOL) wage determinations, is available from the following
website: http://www.dol.gov/whd/govcontracts/dbra.htm.
Communications Towers
For the purposes of the limitations on funding levels only, communications towers are not considered
construction. When applying for construction funds, including communications towers, at the time of
application, recipients must submit evidence of approved zoning ordinances, architectural plans, and any
other locally required planning permits.
When applying for funds to construct communication towers, recipients and subrecipients must submit
evidence that the Federal Communication Commission’s Section 106 review process has been completed
and submit all documentation resulting from that review, with a FEMA Grant Programs Directorate EHP
Screening Form, to FEMA as part of the project’s EHP Review submittal. Recipients and subrecipients
are encouraged to have completed as many steps as possible for a successful EHP review in support of
their proposal for funding (e.g., coordination with their Tribal Historic Preservation Office to identify
potential historic preservation issues and to discuss the potential for project effects; compliance with all
state and local EHP laws and requirements). Projects for which an EA may be needed, as defined in DHS
Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1 and FEMA Instruction 108-1-1,
must also be identified to the FEMA HQ Preparedness Officer within six months of the recipient’s receipt
of the award. Completed EHP review materials for communication tower projects must be submitted no
later than 12 months before the end of the period of performance. EHP policy guidance and the EHP
Screening Form, can be found online at: https://www.fema.gov/media-library/assets/documents/90195.
EHP review materials and an EHP Screening Form should be sent to gpdehpinfo@fema.dhs.gov.
Multiple Purpose or Dual-Use of Funds
Many activities that support the achievement of target capabilities related to terrorism preparedness may
simultaneously support enhanced preparedness for other hazards unrelated to acts of terrorism. See 6 U.S.C.
§ 609(c). However, all THSGP-funded projects must assist recipients and subrecipients in achieving target
capabilities related to preventing, preparing for, protecting against, or responding to acts of terrorism.
THSGP Appendix | May 2022 Page B-11
Whole Community Preparedness
In addition to the Citizen Corps Whole Community Councils and Community Emergency Response Team
(CERT) programs mentioned above, youth preparedness activities are another allowable cost. Bolstering
youth preparedness across the nation is a priority for FEMA as the Agency works with state, local, tribal,
and territorial partners to create a culture of preparedness in the United States. Information on youth-
centric educational curricula, games, planning materials, and other relevant resources can be found at
https://www.ready.gov/kids. Furthermore, FEMA’s Individual and Community Preparedness Division
(ICPD) and regional based Community Preparedness Officers (CPOs) are available to provide grant
recipients with guidance and assistance. Please email FEMA-Prepare@fema.dhs.gov to contact one of the
Agency’s subject matter experts.
The following are examples of youth preparedness activities that grantees are encouraged to undertake as
allowable costs:
• Reach out to a local school board or elementary school to encourage the adoption of the Student
Tools for Emergency Planning (STEP) curriculum. STEP is a classroom-based emergency
preparedness curriculum for 4th- and 5th-graders in an easy, ready-to-teach format. Students will
learn about disasters, emergencies, and hazards, and how to create a disaster supply kit and family
emergency communication plan. An overview of the STEP program along with the instructor
guide and student activity book is available at https://www.ready.gov/student-tools-emergency-
planning-step; and
• Sponsor the creation of a Teen CERT in your jurisdiction. The CERT Program is a national
program of volunteers trained in disaster preparedness and emergency response. Volunteers come
from all ages and all walks of life, including teenagers. Additional information, including a step-
by-step guide on how to start a Teen CERT, is available at https://www.ready.gov/teen-cert.
The following tools are available to order from FEMA’s warehouse free of charge:
• “Prepare with Pedro” is a joint product of FEMA and the American Red Cross. The “Prepare with
Pedro: Disaster Preparedness Activity Book” is designed to teach young children and their
families about how to stay safe during disasters and emergencies. The book follows Pedro around
the United States and offers safety advice through crosswords, coloring pages, matching games,
and more. Additional information, including an ordering form, is available at
https://www.ready.gov/prepare-pedro; and
• The Ready 2 Help card game is a fun way for kids to learn how to respond to emergencies by
working with friends and using skills that will help in a real emergency. Ready 2 Help teaches
five simple steps to stay safe and make a difference until help arrives:
o Stay Safe;
o Stay Calm;
o Get Help;
o Give Info; and
o Give Care.
Ready 2 Help was designed for children ages 8 and up. Additional information, including an ordering
form, is available at https://www.ready.gov/ready-2-help.
Other Allowable Costs
Maintenance and Sustainment
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
THSGP Appendix | May 2022 Page B-12
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses, and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
Grant funds are intended to support the National Preparedness Goal and fund projects that build and
sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and
recover from those threats that pose the greatest risk to the security of the Nation. In order to provide
recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State
Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for
the expansion of eligible maintenance and sustainment costs which must be in (1) direct support of
existing capabilities, (2) must be an otherwise allowable expenditure under the applicable grant program,
and (3) be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally,
eligible costs must also be in support of equipment, training, and critical resources that have previously
been purchased with either federal grant money or any other source of funding other than FEMA
preparedness grant program dollars.
Critical Emergency Supplies
In furtherance of DHS’s mission, critical emergency supplies, such as shelf-stable food products, water,
and basic medical supplies are an allowable expense under THSGP. Prior to allocating grant funds for
stockpiling purposes, each Tribe must have FEMA’s approval of a five-year viable inventory
management plan, an effective distribution strategy, and related sustainment costs if the planned grant
expenditure is over $100,000.
The inventory management plan and distribution strategy, to include sustainment costs, will be developed
and monitored by FEMA. FEMA will provide program oversight and technical assistance as it relates to
the purchase of critical emergency supplies under THSGP. FEMA will establish guidelines and
requirements for the purchase of these supplies under THSGP and monitor development and status of the
Tribe’s inventory management plan and distribution strategy. Linkages between specific projects
undertaken with THSGP funds and strategic goals and objectives will be highlighted through regular
required reporting mechanisms. If grant expenditures exceed the minimum threshold, the five-year
inventory management plan will be developed and monitored by FEMA.
Secure Identification
THSGP funds may be used to support the development and production of enhanced tribal documents
(e.g., Enhanced Tribal Cards) designed to meet the requirements of the Western Hemisphere Travel
Initiative (WHTI). More information on the WHTI may be found at
http://www.dhs.gov/files/programs/gc_1200693579776.shtm and https://www.cbp.gov/travel/us-
citizens/western-hemisphere-travel-initiative.
When completing the Investment Justification, refer to the National Preparedness Goal at for a list of the
core capabilities that best fit the proposed activities and costs. For additional assistance in determining the
core capabilities that fit the proposed WHTI project, please contact the CSID by phone at (800) 368-6498
or by e-mail at askcsid@fema.gov
THSGP Appendix | May 2022 Page B-13
Fidelity Bonds
Reasonable costs of fidelity bonds (or like insurance as provided for by applicable state or tribal laws)
covering the maximum amount of THSGP funds the officer, official, or employee handles at any given
time for all personnel who disburse or approve disbursement of THSGP funds may be allowable if
required by the terms and conditions of the award or if generally required by the tribe in its general
operations. If a fidelity bond is required by a tribe in its general operations, those costs must be charged as
indirect costs. See 2 C.F.R. § 200.427.
Framework for Improving Critical Infrastructure Cybersecurity
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in
implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the
“Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework
gathers existing international standards and practices to help organizations understand, communicate, and
manage their cyber risks. For organizations that do not know where to start with developing a
cybersecurity program, the Framework provides initial guidance. For organizations with more advanced
practices, the Framework offers a way to improve their programs, such as better communication with
their leadership and suppliers about management of cyber risks.
CISA’s Critical Infrastructure Cyber Community C³ Voluntary Program also provides resources to critical
infrastructure owners and operators to assist in adoption of the Framework and managing cyber risks.
Additional information on the Critical Infrastructure Cyber Community C³ Voluntary Program can be
found at http://www.cisa.gov/ccubedvp.
DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in
protecting U.S.-based public and private entities and combines key elements of capabilities under the
“Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the
Cybersecurity Framework. Specifically, ECS offers intrusion prevention and analysis services that help
U.S.-based companies and SLTT governments defend their computer systems against unauthorized
access, exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat
indicators from sensitive and classified Government Furnished Information (GFI). DHS then shares those
indicators with accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to
block certain types of malicious traffic from entering a company’s networks. Groups interested in
subscribing to ECS must contract directly with a CSP in order to receive services. Please visit
http://www.cisa.gov/enhanced-cybersecurity-services for a current list of ECS CSP points of contact.
THSGP Investment Modifications – Changes in Scope or Objective
Changes in scope or objective of the award—including those resulting from intended actions by the
recipient or subrecipients—require FEMA’s prior written approval, in accordance with 2 C.F.R. §§
200.308(c)(1), 200.407. THSGP is competitive, with applications recommended for funding based on
threat, vulnerability, and consequence, and their mitigation of potential terrorist attacks. However,
consistent with 2 C.F.R § 200.308(c)(1), Change in Scope Prior Approval, FEMA requires prior approval
of any change in scope or objective of the grant-funded activity after the award is issued. See 2 C.F.R. §
200.308(b), (c). Scope or objective changes will be considered on a case-by-case basis, provided the
change does not negatively impact the competitive process used to recommend THSGP awards.
Requests to change the scope or objective of the grant-funded activity after the award is made must be
submitted via ND Grants as a Scope Change Amendment. The amendment request must include the
following:
THSGP Appendix | May 2022 Page B-14
• A written request on the recipient’s letterhead, outlining the scope or objective change, including
the approved projects from the IJ, the funds and relative scope or objective significance allocated
to those projects, the proposed changes, and any resulting reallocations as a result of the change
of scope or objective;
• An explanation why the change of scope or objective is necessary;
• How the proposed scope or objective changes to the project support the vulnerabilities and
capability gaps identified in the approved IJ; and
• The request must also address whether the proposed changes will impact the recipient’s ability to
complete the project within the award’s period of performance.
Recipients may not proceed with implementing any scope or objective changes until they receive prior
written approval from FEMA through ND Grants.
NSGP Appendix | May 2022 Page C-1
Program Appendix C:
Nonprofit Security Grant Program (NSGP)
As a reminder, while this appendix contains NSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the NSGP. Please be sure to read the main content of this Manual
in addition to the program-specific appendices.
NSGP grant recipients and subrecipients may only use NSGP grant funds for the purpose set forth in the
grant award and must use funding in a way that is consistent with the statutory authority for the award.
Grant funds may not be used for matching funds for other federal grants or cooperative agreements,
lobbying, or intervention in federal regulatory or adjudicatory proceedings. In addition, federal funds may
not be used to sue the Federal Government or any other government entity.
Pre-award costs are allowable only with the prior written approval of FEMA and if they are included in
the award agreement. To request pre-award costs a written request must be included with the application,
signed by the Authorized Organizational Representative (AOR) of the entity. The letter must outline what
the pre-award costs are for, including a detailed budget break-out of pre-award costs from the post-award
costs, and a justification for approval. The following information outlines general allowable and
unallowable NSGP costs guidance.
NSGP Funding Guidelines
Recipients and subrecipients must comply with all applicable requirements of the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards located at 2 C.F.R. Part 200.
In administering a NSGP grant award, recipients must comply with the following general requirements:
NSGP Priorities
See the annual NSGP NOFO.
Allowable Costs
Management and Administration (M&A)
M&A costs are for activities directly related to the management and administration of the award. M&A
activities are those defined as directly relating to the management and administration of NSGP funds,
such as financial management and monitoring. M&A expenses must be based on actual expenses or
known contractual costs. Requests that are simple percentages of the award, without supporting
justification, will not be allowed or considered for reimbursement.
M&A costs are not operational costs, they are the necessary costs incurred in direct support of the grant or
as a consequence of the grant and should be allocated across the entire lifecycle of the grant. Examples
include preparing and submitting required programmatic and financial reports, establishing and/or
maintaining equipment inventory, documenting operational and equipment expenditures for financial
accounting purposes, and responding to official informational requests from state and federal oversight
authorities. M&A costs include the following categories of activities:
NSGP Appendix | May 2022 Page C-2
• Hiring of full-time or part-time staff or contractors/consultants responsible for activities relating
to the management and administration of NSGP funds. Hiring of contractors/consultants must
follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327; and
• Meeting-related expenses directly related to M&A of NSGP funds.
M&A costs are allowed under this program as described below:
• SAA (Recipient) for NSGP-Urban Area (NSGP-UA) and NSGP-State (NSGP-S) M&A:
SAAs may use and expend up to the percent noted in the relevant fiscal year (FY) NOFO for
M&A purposes (5% for FY 2022) associated with their NSGP-UA and NSGP-S awards. SAAs
must be able to separately account for M&A costs associated with the NSGP-UA award from
those associated with the NSGP-S, and neither can exceed the percent noted in the relevant FY
NOFO (5% of each award for FY 2022).
• Nonprofit (Subrecipient) for NSGP-UA and NSGP-S, and Community Project Funding
M&A: Nonprofit organizations that receive a subaward under this program may use and expend
up to the percent noted in the relevant fiscal year (FY) NOFO for M&A purposes associated with
the subaward.
Indirect (Facilities and Administrative [F&A]) Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
National Incident Management System (NIMS) Implementation
Recipients receiving NSGP funding are strongly encouraged to implement NIMS. NIMS guides all levels
of government, nongovernmental organizations (NGO), and the private sector to work together to prevent,
protect against, mitigate, respond to, and recover from incidents. NIMS provides stakeholders across the
whole community with the shared vocabulary, systems, and processes to successfully deliver the
capabilities described in the National Preparedness System.
Incident management activities require carefully managed resources (personnel, teams, facilities,
equipment, and supplies). NIMS defines a national, interoperable approach for sharing resources,
coordinating, and managing incidents, and communicating information. Incident management refers to
how incidents are managed across all homeland security activities, including prevention, protection,
mitigation, response, and recovery.
Utilization of the standardized resource management concepts such as typing, credentialing, and
inventorying promote a strong national mutual aid capability needed to support delivery of core
NSGP Appendix | May 2022 Page C-3
capabilities. Recipients should manage resources purchased or supported with FEMA grant funding
according to NIMS resource management guidance.
Additional information on resource management and NIMS resource typing definitions and job
titles/position qualifications is on FEMA’s website at https://www.fema.gov/emergency-
managers/nims/components. Additional information about NIMS in general is available at
https://www.fema.gov/emergency-managers/nims.
Allowable Direct Costs
Planning
Funding may be used for security or emergency planning expenses and the materials required to conduct
planning activities. Planning must be related to the protection of the facility and the people within the
facility and should include consideration of access and functional needs considerations as well as those
with limited English proficiency. Planning efforts can also include conducting risk and resilience
assessments on increasingly connected cyber and physical systems, on which security depends, using the
Infrastructure Resilience Planning Framework and related CISA resources. Examples of planning
activities allowable under this program include:
• Development and enhancement of security plans and protocols;
• Development or further strengthening of security assessments;
• Emergency contingency plans;
• Evacuation/Shelter-in-place plans;
• Coordination and information sharing with fusion centers; and
• Other project planning activities with prior approval from FEMA.
Equipment
Allowable costs are focused on target hardening and physical security enhancements. Funding can be
used for the acquisition and installation of security equipment on real property (including buildings and
improvements) owned or leased by the nonprofit organization, specifically in prevention of and/or
protection against the risk of a terrorist attack. This equipment is limited to select items in the following
two sections of items on the Authorized Equipment List (AEL):
• Physical Security Enhancement Equipment (Section 14); and
• Inspection and Screening Systems (Section 15).
In addition to the select items in Sections 14 and 15 listed above, the following equipment is also
allowable:
• Notification and Warning Systems; and
• Radios and Public Warning Systems – Public Address, Handheld, or Mobile.
Unless otherwise stated, equipment must meet all mandatory statutory, regulatory, and FEMA-adopted
standards to be eligible for purchase using these funds, including the Americans with Disabilities Act. In
addition, recipients will be responsible for obtaining and maintaining all necessary certifications and
licenses for the requested equipment, whether with NSGP funding or other sources of funds (seethe
Maintenance and Sustainment section below for more information). In addition, recipients that are using
NSGP funds to support emergency communications equipment activities must comply with the
SAFECOM Guidance on Emergency Communications Grants, including provisions on technical
NSGP Appendix | May 2022 Page C-4
standards that ensure and enhance interoperable communications. This SAFECOM Guidance can be
found at https://www.cisa.gov/safecom/funding.
Recipients and subrecipients may purchase equipment not listed on the AEL, but only if they first seek
and obtain prior approval from FEMA.
Applicants should analyze the cost benefits of purchasing versus leasing equipment, especially high-cost
items and those subject to rapid technical advances. Large equipment purchases must be identified and
explained. For more information regarding property management standards for equipment, please
reference 2 C.F.R. Part 200, including but not limited to 2 C.F.R. §§ 200.310, 200.313, and 200.316. Also
see 2 C.F.R. §§ 200.216, 200.471, and FEMA Policy #405-143-1, Prohibitions on Expending FEMA
Award Funds for Covered Telecommunications Equipment or Services, regarding prohibitions on covered
telecommunications equipment or services.
The installation of certain equipment may trigger EHP requirements. Please reference the EHP sections in
the NOFO and this Manual for more information. Additionally, some equipment installation may
constitute construction or renovation. Please see the Construction and Renovation section of this appendix
for additional information.
Exercises
Funding may be used to conduct security-related exercises. This includes costs related to planning,
meeting space and other meeting costs, facilitation costs, materials and supplies, and documentation.
Exercises afford organizations the opportunity to validate plans and procedures, evaluate capabilities, and
assess progress toward meeting capability targets in a controlled, low risk setting. All shortcomings or
gaps—including those identified for children and individuals with access and functional needs—should
be identified in an improvement plan. Improvement plans should be dynamic documents with corrective
actions continually monitored and implemented as part of improving preparedness through the exercise
cycle.
The Homeland Security Exercise and Evaluation Program (HSEEP) provides a set of guiding principles
for exercise programs, as well as a common approach to exercise program management, design and
development, conduct, evaluation, and improvement planning. For additional information on HSEEP,
refer to https://www.fema.gov/emergency-managers/national-preparedness/exercises/hseep. In
accordance with HSEEP guidance, subrecipients are reminded of the importance of implementing
corrective actions iteratively throughout the progressive exercise cycle. This link provides access to a
sample After Action Report (AAR)/Improvement Plan (IP) template:
https://preptoolkit.fema.gov/web/hseep-resources/improvement-planning. Recipients are encouraged to
enter their exercise data and AAR/IP in the Preparedness Toolkit.
Maintenance and Sustainment
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses, and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
NSGP Appendix | May 2022 Page C-5
Grant funds are intended to support the National Preparedness Goal (the Goal) and fund projects that
build and sustain the core capabilities necessary to prevent, protect against, mitigate the effects of,
respond to, and recover from those threats that pose the greatest risk to the security of the Nation. In order
to provide recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State
Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for
the expansion of eligible maintenance and sustainment costs that must be in (1) direct support of existing
capabilities, (2) must be an otherwise allowable expenditure under the applicable grant program, and (3)
be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible
costs may also support equipment, training, and critical resources that have previously been purchased
with either federal grant or any other source of funding other than FEMA preparedness grant program
dollars.
Construction and Renovation
NSGP funding may not be used for construction and renovation projects without prior written approval
from FEMA. In some cases, the installation of equipment may constitute construction and/or renovation.
If you have any questions regarding whether an equipment installation project could be considered
construction or renovation, please contact your Preparedness Officer. All recipients of NSGP funds must
request and receive prior approval from FEMA before any NSGP funds are used for any construction or
renovation. Additionally, recipients are required to submit a SF-424C Budget and budget detail citing the
project costs and an SF-424D Form for standard assurances for the construction project. The total cost of
any construction or renovation paid for using NSGP funds may not exceed the greater amount of $1
million or 15% of the NSGP award.
All construction and renovation projects require Environmental Planning and Historic Preservation (EHP)
review. Recipients and subrecipients are encouraged to have completed as many steps as possible for a
successful EHP review in support of their proposal for funding (e.g., coordination with their State
Historic Preservation Office to identify potential historic preservation issues and to discuss the potential
for project effects, compliance with all state and local EHP laws and requirements). Projects for which the
recipient believes an Environmental Assessment (EA) may be needed, as defined in DHS Instruction
Manual 023-01-001-01, Revision 01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also
be identified to the FEMA HQ Preparedness Officer within six months of the award and completed EHP
review materials must be submitted no later than 12 months before the end of the period of performance.
Additional information on EHP policy and EHP review can be found online at
https://www.fema.gov/media-library/assets/documents/90195. EHP review packets should be sent to
gpdehpinfo@fema.gov.
NSGP recipients using funds for construction projects must comply with the Davis-Bacon Act (codified
as amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. §
5196(j)(9), which cross-references Davis-Bacon). Grant recipients must ensure that their contractors or
subcontractors for construction projects pay workers no less than the prevailing wages for laborers and
mechanics employed on projects of a character similar to the contract work in the civil subdivision of the
state in which the work is to be performed. Additional information regarding compliance with the Davis-
Bacon Act, including Department of Labor (DOL) wage determinations, is available from the following
website: https://www.dol.gov/whd/govcontracts/dbra.htm.
Training
Nonprofit organizations may use NSGP funds for the following training-related costs:
• Employed or volunteer security staff to attend security-related training within the United States;
NSGP Appendix | May 2022 Page C-6
• Employed or volunteer staff to attend security-related training within the United States with the
intent of training other employees or members/congregants upon completing the training (i.e.,
“train-the-trainer” type courses); and
• Nonprofit organization’s employees, or members/congregants to receive on-site security training.
Allowable training-related costs under the NSGP are limited to attendance fees for training and related
expenses, such as materials, supplies, and/or equipment. Overtime, backfill, and travel expenses are not
allowable costs.
Allowable training topics are limited to the protection of critical infrastructure key resources, including
physical and cybersecurity, target hardening, and terrorism awareness/employee preparedness such as
Community Emergency Response Team (CERT) training, indicators and behaviors indicative of terrorist
threats, Active Shooter training, and emergency first aid training. Additional examples of allowable
training courses include: “Stop The Bleed” training, kits/equipment, and training aids; First Aid and other
novice level “you are the help until help arrives” training, kits/equipment, and training aids; and
Automatic External Defibrillator (AED) and AED/Basic Life Support training, kits/equipment, and
training aids.
Training conducted using NSGP funds must address a specific threat and/or vulnerability, as identified in
the nonprofit organization’s IJ. Training should provide the opportunity to demonstrate and validate skills
learned as well as to identify any gaps in these skills. Proposed attendance at training courses and all
associated costs using the NSGP must be included in the nonprofit organization’s Investment
Justification (IJ).
Contracted Security Personnel
Contracted security personnel are allowed under this program only as described in the NOFO and Manual
and comply with guidance set forth in IB 421b and IB 441. NSGP funds may not be used to purchase
equipment for contracted security. The recipient must be able to sustain this capability in future years
without NSGP funding, and a sustainment plan will be required as part of the closeout package for any
award funding this capability.
Additionally, NSGP recipients and subrecipients may not use more than 50 percent of their awards to pay
for personnel activities unless a waiver is approved by FEMA. For more information on the 50 percent
personnel cap and applicable procedures for seeking a waiver, please see IB 421b, Clarification on the
Personnel Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security Act of
2008 (Public Law 110-412 – the PRICE Act).
Unallowable Costs
The following projects and costs are considered ineligible for award consideration:
• Organization costs, and operational overtime costs;
• Hiring of public safety personnel;
• General-use expenditures;
• Overtime and backfill;
• Initiatives that do not address the implementation of programs/initiatives to build prevention and
protection-focused capabilities directed at identified facilities and/or the surrounding
communities;
• The development of risk/vulnerability assessment models;
• Initiatives that fund risk or vulnerability security assessments or the development of the IJ;
• Initiatives in which federal agencies are the beneficiary or that enhance federal property;
NSGP Appendix | May 2022 Page C-7
• Initiatives which study technology development;
• Proof-of-concept initiatives;
• Initiatives that duplicate capabilities being provided by the Federal Government;
• Organizational operating expenses;
• Reimbursement of pre-award security expenses;
• Cameras for license plate readers/license plate reader software;
• Cameras for facial recognition software;
• Weapons or weapons-related training; and
• Knox boxes.
NSGP Investment Modifications – Changes in Scope or Objective
Changes in scope or objective of the award—whether as a result of intended actions by the recipient or
subrecipients—require FEMA’s prior written approval, in accordance with 2 C.F.R. §§ 200.308(c)(1),
200.407. NSGP is competitive, with applications recommended for funding based on threat, vulnerability,
consequence, and their mitigation to a specific facility/location. However, consistent with 2 C.F.R §
200.308(c)(1), Change in Scope Notification, FEMA requires prior written approval of any change in
scope/objective of the grant-funded activity after the award is issued. See 2 C.F.R. § 200.308(b), (c).
Scope/objective changes will be considered on a case-by-case basis, provided the change does not
negatively impact the competitive process used to recommend NSGP awards. Requests to change the
scope or objective of the grant-funded activity after the award is made must be submitted by the State
Administrative Agency (SAA) via ND Grants as a Scope Change Amendment. The amendment request
must include the following:
• A written request from the NSGP subrecipient on its letterhead, outlining the scope or objective
change, including the approved projects from the subrecipient’s IJ, the funds and relative scope or
objective significance allocated to those projects, the proposed changes, and any resulting
reallocations as a result of the change of scope or objective;
• An explanation why the change of scope or objective is necessary;
• Validation from the SAA that any deviations from the approved IJ are addressed in the
vulnerability assessment submitted by the subrecipient at the time of application; and
• The subrecipient request must also address whether the proposed changes will impact its ability to
complete the project within the award’s period of performance.
FEMA will generally not approve NSGP change-of-scope requests resulting from the following
situations:
• Subrecipients that relocate their facilities after submitting their application who are requesting a
change of scope to allow them to use NSGP funds towards projects at the new facility; or
• Subrecipients that renovate their facilities after submitting their application in cases where the
subsequent renovations would affect the vulnerability/risk assessment upon which the IJ is based.
NSGP project funding is based on the ability of the proposed project to mitigate the risk factors identified
in the IJ. For this reason, FEMA may reject requests to significantly change the physical security
enhancements that are purchased with NSGP funding where FEMA believes approval of the request
would change or exceed the scope of the originally approved project. FEMA will consider all requests to
deviate from the security project as originally proposed on a case-by-case basis, consistent with 2 C.F.R. §
200.308(c)(1).
NSGP Appendix | May 2022 Page C-8
Subrecipients may not proceed with implementing any scope/objective changes until the SAA receives
written approval from FEMA through ND Grants and until the SAA has made any required subaward
modifications.
If a subrecipient is simply making changes to its own budget without impacting the scope or objective of
the subaward, and where the budget changes do not involve other prior approval requirements listed in 2
C.F.R. § 200.407, then the subrecipient does not need the prior approval of the SAA or FEMA. See 2
C.F.R. § 200.308. Instead, the subrecipient is only required to report to the SAA the budget changes.
Similarly, the SAA should report those budget changes to FEMA.
Pass-Through Requirements
Pass-through funding is required under this program. Awards made to the SAA for the NSGP carry
additional pass-through requirements. Pass-through is defined as an obligation on the part of the state to
make subawards to selected nonprofit organizations. The SAA must provide funds awarded under NSGP
to successful nonprofit applicants within 45 days of receipt of the funds. A letter of intent (or equivalent)
to distribute funds is not sufficient. Award subrecipients that are selected for funding under this program
must be provided with funding within 45 days from the date the funds are first made available to the
recipient so that they can initiate implementation of approved investments.
For the SAA to successfully meet the pass-through requirement and provide funding to the subrecipients,
the SAA must meet the following four requirements:
• There must be some action by the SAA to establish a firm commitment to award the funds to the
selected nonprofit organization;
• The action must be unconditional on the part of the SAA (i.e., no contingencies for availability of
SAA funds);
• There must be documentary evidence of the commitment of the award of funding to the selected
nonprofit organization; and
• The SAA must communicate the terms of the subaward to the selected nonprofit organization.
If a nonprofit organization is selected for an NSGP award and elects to decline the award, the SAA must
notify their FEMA Preparedness Officer. The SAA may not re-obligate to another subrecipient without
prior approval. “Receipt of the funds” occurs either when the SAA accepts the award or 15 calendar days
after the SAA receives notice of the award, whichever is earlier. SAAs are sent notification of NSGP
awards via the ND Grants system. If an SAA accepts its award within 15 calendar days of receiving
notice of the award in the ND Grants system, the 45-calendar day pass-through period will start on the
date the SAA accepted the award. Should an SAA not accept the NSGP award within 15 calendar days of
receiving notice of the award in the ND Grants system, the 45-calendar days pass-through period will
begin 15 calendar days after the award notification is sent to the SAA via the ND Grants system.
It is important to note that the period of performance (POP) start date does not directly affect the start of
the 45-calendar day pass-through period. For example, an SAA may receive notice of the NSGP award on
August 20, 2022, while the POP dates for that award are September 1, 2022, through August 31, 2025. In
this example, the 45-day pass-through period will begin on the date the SAA accepts the NSGP award or
September 4, 2022 (15 calendar days after the SAA was notified of the award), whichever date occurs
first. The POP start date of September 1, 2022, would not affect the timing of meeting the 45-calendar
day pass-through requirement.
NSGP Appendix | May 2022 Page C-9
SAM/UEI Requirements for Recipients and Subrecipients
As the direct applicant and recipient of NSGP funding, the SAA is required to have a Unique Entity
Identifier (UEI) number and be registered in the System for Award Management (SAM) and must
maintain the currency of the SAA's information in SAM until the SAA submits the final financial report
required under the award or receives final payment, whichever is later. First tier subrecipients, including
nonprofit organizations under the NSGP, will only be required to register in SAM.gov to obtain the UEI,
but will not be required to maintain an active registration in SAM.gov. Further guidance on obtaining
a UEI in SAM.gov can be found at GSA UEI Update and here SAM.gov Update.
TSGP Appendix | May 2022 Page D-1
Program Appendix D:
Transit Security Grant Program (TSGP)
As a reminder, while this appendix contains TSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the TSGP. Please be sure to read the main content of this Manual
in addition to the program-specific appendices.
TSGP grant recipients may only use TSGP grant funds for the purpose set forth in the Notice of Funding
Opportunity (NOFO), and all investments must be consistent with the statutory authority for the award.
Grant funds may not be used for matching funds for other federal awards, lobbying, or intervention in
federal regulatory or adjudicatory proceedings. In addition, federal funds may not be used to sue the
Federal Government or any other government entity.
TSGP Funding Guidelines
Costs charged to a TSGP award must be consistent with the Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, located at 2 C.F.R. Part 200. For more
information on 2 C.F.R. Part 200, please see Information Bulletin (IB) 400, FEMA’s Implementation of 2
C.F.R. Part 200, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (“Super Circular” or “Omni Circular”), dated December 23, 2014, regarding FEMA’s
implementation of these provisions prior to the recent 2020 revisions. For information on the recent
revisions to these regulations, see 2 CFR Grants Management Policy Updates and
www.performance.gov/CAP/grants/.
Pre-Award Costs
Pre-award costs are not allowable and will not be approved, with the exception of costs resulting from
pre-award grant writing services provided by an independent contractor that shall not exceed $1,500.00.
See below for more information on these costs.
TSGP Priorities
See the annual TSGP NOFO.
Security Plan Requirements
The following information regarding security plan requirements is provided in 6 U.S.C. § 1134(c)(2):
Security plans should include the following, as appropriate:
• A prioritized list of all items included in the public transportation agency’s security assessment
that have not yet been addressed;
• A detailed list of any additional capital and operational improvements identified by DHS or the
public transportation agency and a certification of the public transportation agency’s technical
capacity for operating and maintaining any security equipment that may be identified in such list;
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• Specific procedures to be implemented or used by the public transportation agency in response to
a terrorist attack, including evacuation and passenger communication plans and appropriate
evacuation and communication measures for the elderly and individuals with disabilities;
• A coordinated response plan that establishes procedures for appropriate interaction with state and
local law enforcement agencies, emergency responders, and federal officials in order to
coordinate security measures and plans for response in the event of a terrorist attack or other
major incident;
• A strategy and timeline for conducting training under 49 C.F.R. § 1570.109(b) and 49 C.F.R. Part
1582;
• Plans for providing redundant and other appropriate backup systems necessary to ensure the
continued operation of critical elements of the public transportation system in the event of a
terrorist attack or other major incident;
• Plans for providing service capabilities throughout the system in the event of a terrorist attack or
other major incident in the city or region which the public transportation system serves;
• Methods to mitigate damage within a public transportation system in case of an attack on the
system, including a plan for communication and coordination with emergency responders; and
• Other actions or procedures as the Secretary of Homeland Security determines are appropriate to
address the security of the public transportation system.
Allowable Direct Costs
Specific investments made in support of the funding priorities in the annual TSGP NOFO generally fall
into one of the following six allowable expense categories:
• Planning;
• Operational Activities;
• Equipment and Capital Projects;
• Training and Awareness Campaigns;
• Exercises; and
• Management and Administration.
The following provides guidance on allowable costs within each of these areas:
Planning
Planning activities address the Soft Targets/Crowded Places; Cybersecurity; and Planning Priorities.
TSGP funds may be used for the following types of planning activities:
• Development and enhancement of system-wide security risk management plans that ensure the
continuity of essential functions, to include cyber;
• Development or further strengthening of continuity plans, response plans, station action plans,
risk assessments, and asset-specific remediation plans;
• Development or further strengthening of security assessments, including multi-agency and multi-
jurisdictional partnerships and conferences to facilitate planning activities;
• Hiring of full or part-time staff and contractors or consultants to assist with planning activities
only to the extent that such expenses are for the allowable activities within the scope of the grant
(not for the purpose of hiring public safety personnel); hiring of contractors/consultants must
follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327;
• Materials required to conduct planning activities;
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• Conducting risk and resilience assessments on increasingly connected cyber and physical
systems, on which security depends, using the Infrastructure Resilience Planning Framework and
related CISA resources;
• Planning activities related to alert and warning capabilities; and
• Other project planning activities with prior approval from FEMA.
Operational Activities
Operational Activities address the Soft Targets/Crowded Places Priority.
FEMA encourages applicants to develop innovative operational approaches to enhance the security of
transit systems. Projects that use visible, unpredictable deterrence, to include operational packages
dealing with explosive detection canine teams, mobile screening teams, and anti-terrorism teams, directly
support enhancing the protection of soft targets and crowded places. Implementation of one of the three
Operational Package (OPack) models discussed below complements existing security systems and
provides an appropriate, practical, and cost-effective means of protecting assets.
Agencies may submit Investment Justifications (IJ) to fund transit security police forces/law enforcement
providers for patrols and activities on overtime, such as directed patrols, additional canine teams, mobile
screening teams, or anti-terrorism team patrols. These activities must be dedicated to the transit
environment and must be anti-terrorism in nature. Agencies must identify the type of activity, length of
operation (hours), number of personnel, and cost based on length of operation and personnel. Agencies
should also provide a risk-based justification for the request, to include linkage to a known event, such as
hosting a significant regional sporting or political event; or a period of heightened awareness, such as a
national holiday. Three OPack types have been developed to support operational activities and are
available for funding under the TSGP:
• Explosives Detection Canine Teams (EDCTs). When combined with the existing capability of a
transit security/police force, the added value provided through the addition of an EDCT is
significant. EDCTs are a proven, reliable resource to detect explosives and are a key component
in a balanced counter-sabotage program. The TSGP will provide funds to establish dedicated
security/police force canine teams. Each canine team will be composed of one dog and one
handler.
• Anti-Terrorism Teams (ATTs). The ATT capability provided through TSGP funding is for
uniformed, dedicated transit patrols on a normal operational basis, rather than using teams only
for a surge capacity as provided by FEMA in the past. ATTs do not supersede other local transit
security forces; rather, they augment current capabilities. Each ATT will consist of four
individuals, including two overt elements (e.g., uniformed transit sector law enforcement officer,
canine team, mobile explosive screeners), and two discreet observer elements.
• Mobile Explosive Screening Teams (MESTs). The MEST OPack will allow recipients the
flexibility to deploy combinations of certified explosive ordinance technicians with mobile
explosive screening technologies, including during local National Special Security Events. This
screening technology will be coupled with mobile explosive screening technologies. Each MEST
should have a minimum of two members and one mobile explosive screening apparatus.
Note: Funds for canine teams may not be used to fund drug detection and apprehension technique
training. Only explosives detection training for the canine teams will be funded.
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Funding Availability for OPacks
OPacks have the potential to be funded for up to a 36-month period from the award date. The monetary
figures presented below are stated in terms of cost per period of performance (which indicates
actual/complete funding for the 36-month period). Additionally, any OPack costs after the 36-month
period of performance (including expenses related to the maintenance, personnel, equipment, etc.) are the
responsibility of the applicable transit system. If these positions are not sustained, the public
transportation agency may not be eligible for this personnel support in the future. The table below
identifies the maximum funding available for the different OPack types.
Available Funding for OPacks
Operational Package Maximum Funding per Year
(12 months)
Maximum Funding per Period of
Performance (36 months)
EDCT $150,000 per team $450,000 per team
ATT $500,000 per team $1,500,000 per team
MEST $600,000 per team $1,800,000 per team
OPack Requirements
TSGP OPack funds may be used for new positions or to sustain existing capabilities/programs (e.g.,
canine teams) already supported by the recipient. Applicants submitting IJs for both new OPacks and
sustainment funding for existing OPacks must clearly indicate which is their highest priority if funding is
available for only one of the IJs. Additionally, applicants must provide the number of existing teams
(EDCT, ATT, and MEST) already in place with either in-house funding or TSGP funding. The table
below identifies specific OPack requirements.
OPack Requirements
Operational Package Requirements
Explosives Detection Canine Teams Please refer to the pages below for detailed information regarding
EDCTs under the TSGP.
Five-Year Security Capital Plan and Operational Sustainment
Applicant requests for OPack funding must include the submission of a Five-Year Security Capital
and Operational Sustainment Plan in ND Grants. This plan must include how the agency proposes to
implement capital projects and demonstrate how the agency will sustain the operational investments
(including officers hired with federal funding) and capabilities after grant funding has been expended.
Requests for OPacks will not be funded if the applicant does not have a Security Capital and
Operational Sustainment Plan.
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Operational Package Requirements
Anti-Terrorism Teams
Specific for the Canine Team within the ATT:
• Each canine team, composed of one dog and one handler,
must be certified by an appropriate, qualified organization;
• Canines should receive an initial basic training course and
also weekly maintenance training sessions thereafter to
maintain the certification;
• The basic training averages 10 weeks for the team, with
weekly training and daily exercising (comparable training and
certification standards, such as those promulgated by the
Transportation Security Administration (TSA) Explosive
Detection Canine Program), the National Police Canine
Association (NPCA), the United States Police Canine
Association (USPCA), or the International Explosive
Detection Dog Association (IEDDA) may be used to meet
this requirement;
• The individuals hired for the covert and overt elements must
be properly trained law enforcement officers; and
• Certifications should be on file with the recipient and must be
made available to FEMA upon request
Mobile Explosives Screening Team Certifications should be on file with the recipient and must be
made available to FEMA upon request.
Allowable Expenses for OPacks
The below table identifies allowable expenses for the various OPacks. Please see the inserted notes for
clarification of certain allowable costs.
Allowable Expenses for OPacks
Operational Package Salary and Fringe Benefits Training and Certification Equipment Costs Purchase and Train a Canine Canine Costsb 1) EDCTa c
2) ATT
3) MEST d
a Travel costs associated with training for personnel, handlers, and canines are allowable
b Canine costs include but are not limited to veterinary, housing, and feeding costs
c One type of allowable training is training specific to the detection of common explosives odors.
d Equipment and other costs can include but are not limited to explosives detection; stainless steel search tables;
consumables such as gloves, swabs, and alcohol; and land mobile radios
Specific Guidance on EDCTs
EDCT Certification. Each EDCT, composed of one dog and one handler, must be certified by an
appropriate, qualified organization. TSA-certified EDCTs will meet or exceed certification standards set
by the TSA National Explosives Detection Canine Team Program (NEDCTP). Recipient EDCTs that do
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not participate in the NEDCTP will be required to certify annually under their respective agency, local
and state regulations. The recipient (i.e., TSGP-grant supported) will maintain certification, utilization,
and training data to show their compliance in meeting or exceeding those guidelines set forth by the
Scientific Working Group on Dog and Orthogonal Detection Guidelines (SWGDOG), as of September
14, 2007, in addition to requirements set forth in the NOFO.
EDCT Submission Requirements
1) The recipient will ensure that a written security procedure plan exists for the safekeeping of all
explosive training aids, including safe transportation. The recipient will document the removal,
use, and return of explosive training aids used during training exercises or for any other reason.
The plan and all documentation must be made available to FEMA upon request;
2) The recipient will comply with requirements for the proper storage, handling, and transportation
of all explosive training aids in accordance with the Bureau of Alcohol, Tobacco, Firearms and
Explosives’ Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law and Regulation;
3) The recipient will ensure that certified EDCTs are available to respond to situations 24 hours a
day, seven days per week on an on-duty or off-duty on call basis. If TSGP-funded EDCTs are not
available, other non-TSGP-funded EDCTs may be utilized for this response. The intent is to
provide maximum coverage during peak operating hours and to maintain the ability to promptly
respond to threats that affect public safety or mass transit operations;
4) EDCTs under this grant are single purpose and will be trained to detect “live” explosives only not
“simulated” explosives. EDCTs must not have received previous training to detect any other
substances;
5) Recipient EDCTs will ensure that each EDCT receives on-site proficiency training at a minimum
of four hours per week per duty cycle. This training shall include, but not be limited to mass
transit passenger cars, terminal/platform, luggage, freight/warehouse, and vehicles. Complete,
detailed, and accurate training records must be maintained for all proficiency training conducted
by each EDCT. These records must be made available to FEMA upon request;
6) The TSGP grant recipient will conduct appropriate training or other canine activities, within view
of the public, to increase public awareness of EDCTs and provide a noticeable deterrent to acts
which affect public safety or mass transit operations. Recipient EDCTs will also ensure that such
activities include, over a period of time, a presence in operational areas of the mass transit system
during peak and off-peak hours. The recipient agrees that EDCTs will be utilized in the field at
least 80% of their duty time, annually;
7) Recipient EDCTs will provide safe and sanitary kennel facilities for program canines, and these
costs may be allowable with prior approval by FEMA. This applies to kenneling canines at the
mass transit system, handlers’ residences, or commercial boarding facilities. Canines must not be
left in makeshift accommodations or without proper supervision, protection, and care. The
recipient will ensure that canines are transported on-duty and off-duty in vehicles configured with
adequate temperature control, padding and screening to ensure proper health, safety, and security;
and
8) Recipient EDCTs will ensure that adequate routine and emergency veterinary care are provided
for all canines.
Note: FEMA reserves the right to conduct an on-site operational and record review upon 48-hour notice
to ensure compliance with applicable federal regulations.
Equipment and Capital Projects
Equipment and Capital Projects address the Soft Targets/Crowded Places; Cybersecurity; and
Equipment/Capital Projects Priorities.
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Priority projects include Top Transit Asset List (TTAL) risk remediation and protection of other high-
risk, high-consequence areas or systems that have been identified through system-wide risk assessments.
These costs include:
• Projects related to physical security enhancements at rail and bus stations in Urban Area Security
Initiative (UASI) jurisdictions including security cameras, security screening equipment for
people and baggage, and access control (e.g., fences, gates, barriers, etc.); and
• Projects related to cybersecurity of access control, sensors, security cameras, badge/ID readers,
Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems,
process monitors and controls, etc. or passenger/vehicle/cargo security screening equipment
support. Cybersecurity assessments are allowable.
Equipment Acquisition
TSGP funds must comply with IB 426. TSGP funds may be used for the following categories of
equipment. A comprehensive listing of allowable equipment categories and types is found in the
Authorized Equipment List (AEL). These costs include:
• Personal protection equipment;
• Explosive device mitigation and remediation equipment;
• Chemical, biological, radiological, nuclear, and explosive (CBRNE) operational search and
rescue equipment, logistical support equipment, reference materials, or incident response vehicles
• Interoperable communications equipment, including alert and warning capabilities;
• Components or systems needed to address flaws in the computerized systems that control
generators, switching stations, and electrical substations as well as other threats to infrastructure
critical to the U.S. economy;
• Detection Equipment;
• Power equipment;
• Terrorism incident prevention equipment; and
• Physical security enhancement equipment.
Recipients and subrecipients may purchase equipment not listed on the AEL, but only if they first seek
and obtain prior approval from FEMA.
Unless otherwise noted, equipment must be certified as meeting required regulatory and FEMA-adopted
standards to be eligible for purchase using TSGP funds. Equipment must comply with the Occupational
Safety and Health Act requirement for certification of electrical equipment by a nationally recognized
testing laboratory and demonstrate compliance with relevant FEMA-adopted standards through a
supplier’s declaration of conformity with appropriate supporting data and documentation per International
Organization for Standardization/International Electro-technical Commission (ISO/IEC) 17050, Parts One
and Two. Agencies must have all necessary certifications and licenses for the requested equipment, as
appropriate, prior its purchase. DHS adopted standards are found at https://www.dhs.gov/dhs-
implementation-statement-regarding-standard-terms-and-conditions-research-grants. In addition,
recipients that are using TSGP funds to support emergency communications equipment activities must
comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on
technical standards that ensure and enhance interoperable communications. This SAFECOM Guidance
can be found at https://www.cisa.gov/safecom/funding.
Equipment: Requirements for Small Unmanned Aircraft Systems
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and also include a description of the policies and procedures in place to safeguard individuals’
TSGP Appendix | May 2022 Page D-8
privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or otherwise use the
sUAS equipment. SUAS policies are not required at the time of application but must be received and
approved by FEMA prior to obligating TSGP funds. All grant-funded procurements must be executed in a
manner compliant with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. For recipients
that use TSGP funds for sUAS, FEMA advises that there is a general privacy concern related to the use of
this equipment if the data the devices collect is transmitted to servers not under the control of the
operator. It has been reported that some manufacturers of sUAS encrypt data and send that data to servers
outside the United States. The U.S. Department of Homeland Security’s Privacy Office suggests the
recipient fully explore data transmission and storage issues with vendors to reduce the possibility of data
breaches.
Additionally, the Joint Explanatory Statement (JES) accompanying the FY 2022 DHS Appropriations Act
further requires recipients to certify they have reviewed the Industry Alert on Chinese Manufactured
Unmanned Aircraft Systems, and completed a risk assessment that considers the proposed use of foreign-
made sUAS to ascertain potential risks (e.g., privacy, data breaches, cybersecurity, etc.) related to foreign-
made versus domestic sUAS.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA alerted of an advisory guidance document issued by DHS, the Department of
Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.
The purpose of the advisory guidance document is to help non-federal public and private entities better
understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate
threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
representations of the systems’ legality or functionality. Please also see the DHS press release on this
topic for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-
technology-detect-and-mitigate-unmanned-aircraft.
Cybersecurity Projects
TSGP funds may be used for projects that enhance the cybersecurity of:
• Access controls, sensors, security cameras, badge/ID readers, ICS/SCADA systems, process
monitors and controls (such as firewalls, network segmentation, predictive security cloud, etc.);
and
• Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable).
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in
implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the
“Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework
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gathers existing international standards and practices to help organizations understand, communicate, and
manage their cyber risks. For organizations that do not know where to start with developing a
cybersecurity program, the Framework provides initial guidance. For organizations with more advanced
practices, the Framework offers a way to improve their programs, such as better communication with
their leadership and suppliers about management of cyber risks.
The Cybersecurity and Infrastructure Security Agency’s (CISA) Critical Infrastructure Cyber Community
C³ Voluntary Program also provides resources to critical infrastructure owners and operators to assist in
adoption of the Framework and managing cyber risks. Additional information on the Critical
Infrastructure Cyber Community C³ Voluntary Program can be found at http://www.cisa.gov/ccubedvp.
DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in
protecting U.S.-based public and private entities and combines key elements of capabilities under the
“Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the
Cybersecurity Framework. Specifically, ECS offers intrusion prevention and analysis services that help
U.S.-based companies and SLTT governments defend their computer systems against unauthorized
access, exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat
indicators from sensitive and classified Government Furnished Information (GFI). DHS then shares those
indicators with accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to
block certain types of malicious traffic from entering a company’s networks. Groups interested in
subscribing to ECS must contract directly with a CSP in order to receive services. Please visit
http://www.cisa.gov/enhanced-cybersecurity-services-ecs for a current list of ECS CSP points of contact.
Capital (Construction) Projects Guidance
Recipients must obtain written approval from FEMA prior to the use of any TSGP funds for construction
or renovation projects. When applying for construction funds, including communications towers, at the
time of application, recipients must submit evidence of approved zoning ordinances, architectural plans,
and any other locally required planning permits. Additionally, recipients are required to submit a SF-424C
and budget detail citing the project costs and an SF-424D Form for standard assurances for the
construction project.
All construction and renovation projects require Environmental Planning and Historic Preservation (EHP)
review. Recipients are also encouraged to have completed as many steps as possible for a successful EHP
review in support of their proposal for funding (e.g., coordination with their State Historic Preservation
Office to identify potential historic preservation issues and to discuss the potential for project effects;
compliance with all state and local EHP laws and requirements).
Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in
DHS Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1 and FEMA Instruction
108-1-1, instances must also be identified to the FEMA HQ Preparedness Officer within the first six
months of the award, regardless of the period of performance. Completed EHP review materials for
construction and communication tower projects must be submitted no later than 12 months before the end
of the period of performance. EHP policy guidance and the EHP Screening Form, can be found online at
https://www.fema.gov/media-library/assets/documents/90195. EHP review materials should be sent to
gpdehpinfo@fema.dhs.gov.
Training and Awareness Campaigns
Training and Awareness Campaigns address the Soft Targets/Crowded Places; Cybersecurity; and
Training and Awareness Campaign Priorities.
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Training
TSGP funds may be used for the following training activities:
• Training Topics. Priority topics include active shooter training, security training for employees,
and public awareness/preparedness campaigns.
• Training Workshops. Grant funds may be used to plan and conduct training workshops to
include costs related to planning, meeting space and other meeting costs, facilitation costs,
materials and supplies, travel, and training plan development. Recipients are strongly encouraged
to use free public space/locations/facilities, whenever available, prior to the rental of
space/locations/facilities. Training should provide the opportunity to demonstrate and validate
skills learned, as well as to identify any gaps in these skills. Any training or training gaps,
including those for children and individuals with disabilities or access and functional needs,
should be identified in an After-Action Report/Improvement Plan (AAR/IP) and addressed in the
training cycle.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff or
contractors/consultants may be hired to support training-related activities. Hiring of
contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R.
§§ 200.317-200.327. Reimbursement of these costs should conform with the policies of the state
or local unit(s) of government or the awarding agency, whichever is applicable. Such costs must
be included within the funding allowed for program management personnel expenses, which must
not exceed 10% of the total allocation. Dual compensation is unallowable. That is, an employee
of a unit of government may not receive compensation from their unit or agency of government
and from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such
work may benefit both activities. Personnel hiring, overtime, and backfill expenses are permitted
under this grant only to the extent that such expenses are for the allowable activities within the
scope of the grant.
• Overtime and Backfill Costs. The entire amount of overtime costs, including payments related
to backfilling personnel, that are the direct result of attendance at FEMA and approved training
courses and programs are allowable. Reimbursement of these costs should follow the policies of
the state or local unit(s) of government or the awarding agency, whichever is applicable. In no
case is dual compensation allowable.
• Travel. Domestic travel costs (e.g., airfare, mileage, per diem, and hotel) are allowable as
expenses by employees who are on travel status for official business related, approved training,
subject to the restrictions at 2 C.F.R. Part 200. International travel is not an allowable expense.
• Supplies. Supplies, items that are expended or consumed during the course of the planning and
conduct of the training project(s) (e.g., gloves and non-sterile masks), are allowable expenses.
• Funds Used to Develop, Deliver, and Evaluate Training, including costs related to
administering the training, planning, scheduling, facilities, materials and supplies, reproduction of
materials, and equipment are allowable expenses. Training should provide the opportunity to
demonstrate and validate skills learned, as well as to identify any gaps in these skills. Any
training or training gaps, including those for children and individuals with disabilities or access
and functional needs, should be identified in the AAR/IP and addressed in the training cycle.
Recipients are encouraged to use existing training rather than developing new courses. When developing
new courses, recipients are encouraged to apply the Analysis, Design, Development, Implementation, and
Evaluation (ADDIE) model of instruction design. Information on FEMA-approved training can found at
http://www.firstrespondertraining.gov/.
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Awareness Campaigns
TSGP funds may be used for the development and implementation of awareness campaigns to raise
public awareness of indicators of terrorism and terrorism-related crime, and for associated efforts to
increase the sharing of information with public and private sector partners, including nonprofit
organizations. DHS currently sponsors or supports a number of awareness campaigns. Please review
materials, strategies, and resources at https://www.dhs.gov/dhs-campaigns before embarking on the
development of an awareness campaign for local constituencies and stakeholders.
Note: DHS requires that all public and private sector partners wanting to implement and/or expand the
DHS “If You See Something, Say Something®” campaign using grant funds work directly with the DHS
Office of Partnership and Engagement (OPE). This will help ensure that the awareness materials (e.g.,
videos, posters, trifolds, etc.) remain consistent with DHS’s messaging and strategy for the campaign and
compliant with the initiative’s trademark, which is licensed to DHS by the New York Metropolitan
Transportation Authority. Coordination with OPE, through the Campaign’s Office (seesay@hq.dhs.gov),
must be facilitated by the FEMA HQ Preparedness Officer.
Exercises
Exercise activities address the Soft Targets/Crowded Places; Cybersecurity; and Exercises Priorities.
TSGP funds may be used for the following exercise activities:
• Funds Used to Design, Develop, Conduct and Evaluate an Exercise. This includes costs
related to planning, meeting space, and other meeting costs, facilitation costs, materials and
supplies, travel, and documentation. Exercises afford organizations the opportunity to validate
plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets
in a controlled, low risk setting. Any shortcoming or gap identified, including those for children
and individuals with disabilities or access and functional needs, should be identified in an
effective corrective action program that includes development of improvement plans that are
dynamic documents, with corrective actions continually monitored and implemented as part of
improving preparedness through the exercise cycle.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be
hired to support exercise-related activities. In order to be eligible for reimbursement, the costs for
hiring staff must conform to the policies of the non-federal entity and federal statutes, where
applicable. See, e.g., 2 C.F.R. § 200.430(a). The costs for hiring contractors or consultants must
comply with the applicable federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. The
costs for hiring staff, consultants, or contractors to support exercise-related activities costs must
be included within the funding allowed for program management personnel expenses, which must
not exceed 10% of the total allocation. Dual compensation is never allowable, meaning, in other
words, that an employee of a unit of government may not receive compensation from their unit or
agency of government and from an award for a single period of time (e.g., 1:00 p.m. to 5:00
p.m.), even though their work may benefit both entities. Personnel hiring, overtime, and backfill
expenses are permitted under this grant only to the extent that such expenses are for the allowable
activities within the scope of the grant.
• Overtime and Backfill Costs. The entire amount of overtime costs, including payments related
to backfilling personnel, which are the direct result of time spent on the design, development and
conduct of exercises are allowable expenses. These costs are allowed only to the extent the
payment for such services is in accordance with the policies of the state or unit(s) of local
government and has the approval of the state or the awarding agency, whichever is applicable.
Dual compensation is never allowable.
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• Travel. Domestic travel costs are allowable as expenses by employees who are on travel status
for official business related to the planning and conduct of exercise project(s), subject to the
restrictions at 2 C.F.R. Part 200. International travel is not an allowable expense.
• Supplies. Supplies are items that are expended or consumed during the course of the planning
and conduct of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective
equipment).
• Other Items. These costs include the rental of space/locations for exercise planning and
executing, rental of equipment, etc. Recipients are encouraged to use free public
space/locations/facilities, whenever available, prior to the rental of space/locations/facilities.
These also include costs that may be associated with inclusive practices and the provision of
reasonable accommodations and modifications to provide full access for children and adults with
disabilities.
Management and Administration (M&A)
Management and administration costs are allowed under this program. M&A costs are activities directly
related to managing and administering the award. Recipients may use up to 5% of the amount of the
award for their M&A.
FY 2022 TSGP funds may be used for the following M&A costs:
• Hiring of full-time or part-time staff, including contractors and consultants, to execute the
following:
o Management of the current fiscal year TSGP Award;
o Design and implementation of the current fiscal year TSGP submission meeting
compliance with reporting/data collection requirements, including data calls;
o Information collection and processing necessary to respond to FEMA data calls;
o Domestic-only travel expenses related to TSGP grant administration, in compliance with
2 C.F.R. Part 200; and
o Acquisition of authorized office equipment, including personal computers or laptops for
TSGP M&A purposes.
Allowable Indirect Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
Unallowable Costs
Specific unallowable costs include:
TSGP Appendix | May 2022 Page D-13
• Grant funds must comply with IB 426 and may not be used for the purchase of the following
equipment: firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft,
vessels, or vehicles of any kind with weapons installed. Additional prohibited equipment
expenditures include items unrelated to grant allowable activities, such as general-use software,
general-use computers, and related equipment (other than for allowable M&A activities or
otherwise associated preparedness or response functions), general-use vehicles, and licensing
fees;
• Personnel costs (except as detailed above);
• Activities unrelated to the completion and implementation of the TSGP; and
• Other items not in accordance with the AEL or not previously listed as allowable costs.
Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses, and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
Grant funds are intended to support the National Preparedness Goal and fund projects that build and
sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and
recover from those threats that pose the greatest risk to the security of the Nation. In order to provide
recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State
Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for
the expansion of eligible maintenance and sustainment costs that must be in (1) direct support of existing
capabilities; (2) must be an otherwise allowable expenditure under the applicable grant program, and (3)
be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible
costs may also be in support of equipment, training, and critical resources that have previously been
purchased with either federal grant or any other source of funding other than FEMA preparedness grant
program dollars.
Encouraged Use of Certain Products Produced in the United States
Pursuant to Executive Order 13858, “Strengthening Buy-American Preferences for Infrastructure
Projects,” FEMA encourages non-federal entities under this grant program to use, to the greatest extent
practicable and consistent with the law, iron and aluminum as well as steel, cement, and other
manufactured products produced in the United States, in projects funded by an award under this grant
program affecting surface transportation, including roadways, bridges, railroads, and transit; aviation;
ports, including navigational channels; water resources projects; energy production, generation, and
storage, including from fossil-fuels, renewable, nuclear, and hydroelectric sources; electricity
transmission; gas, oil, and propane storage and transmission; electric, oil, natural gas, and propane
distribution systems; broadband internet; pipelines; stormwater and sewer infrastructure; drinking water
infrastructure; and cybersecurity. Notwithstanding this encouragement, non-federal entities must take care
that all procurements and contract actions are consistent with law, the Preparedness Grants Manual and
TSGP Appendix | May 2022 Page D-14
applicable appendices, the grant program’s NOFO, and the federal procurement standards at 2 C.F.R. §§
200.317-200.326.
IBSGP Appendix | May 2022 Page E-1
Program Appendix E:
Intercity Bus Security Grant Program (IBSGP)
As a reminder, while this appendix contains IBSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the IBSGP. Please be sure to read the main content of this Manual
in addition to the program-specific appendices.
IBSGP grant recipients may only use IBSGP grant funds for the purpose set forth in the Notice of
Funding Opportunity (NOFO), and all investments must be consistent with the statutory authority for the
award. Grant funds may not be used for matching funds for other federal awards, lobbying, or
intervention in federal regulatory or adjudicatory proceedings. In addition, federal funds may not be used
to sue the Federal Government or any other government entity.
IBSGP Funding Guidelines
Costs charged to an IBSGP award must be consistent with the Uniform Administrative Requirements,
Cost Principles, and Audit Requirements for Federal Awards, located at 2 C.F.R. Part 200. For more
information on 2 C.F.R. Part 200, please see IB 400 regarding FEMA’s implementation of these
provisions prior to the recent 2020 revisions. For information on the recent revisions to these regulations,
see 2 CFR Grants Management Policy Updates.
IBSGP Priorities
See the annual IBSGP NOFO.
Pre-Award Costs
Pre-award costs are not allowable and will not be approved, with the exception of costs resulting from
pre-award grant writing services provided by an independent contractor that shall not exceed $1,500. See
the IBSGP NOFO for more information.
Allowable Direct Costs
Specific investments made in support of the funding priorities discussed in the annual IBSGP NOFO
generally fall into one of the following six allowable expense categories:
1. Planning;
2. Operational Activities;
3. Equipment and Capital Projects;
4. Training and Awareness Campaigns;
5. Exercises; and
6. Management and Administration.
The following provides guidance on allowable costs within each of these areas.
IBSGP Appendix | May 2022 Page E-2
Planning
Planning activities should address the Soft Targets/Crowded Places; Cybersecurity; and Planning
Priorities.
IBSGP funds may be used for the following types of planning activities:
• Development and enhancement of system-wide security risk management plans, to include cyber;
• Development or further strengthening of continuity of operations plans, response plans, station
action plans, risk assessments, and asset-specific remediation plans;
• Development or further strengthening of security assessments, including multi-agency and multi-
jurisdictional partnerships and conferences to facilitate planning activities;
• Hiring of full- or part-time staff and contractors or consultants to assist with planning activities
only to the extent that such expenses are for the allowable activities within the scope of the grant
(not for the purpose of hiring public safety personnel); hiring of contractors/consultants must
follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327;
• Materials required to conduct planning activities;
• Conducting risk and resilience assessments on increasingly connected cyber and physical
systems, on which security depends, using the Infrastructure Resilience Planning Framework and
related CISA resources;
• Planning activities related to alert and warning capabilities; and
• Other project planning activities with prior approval from FEMA.
Operational Activities
Operational Activities should address the Soft Targets/Crowded Places Priority.
FEMA encourages applicants to develop innovative operational approaches to enhance the security of
transportation systems. Examples include:
• Establishing or improving emergency communication systems linking drivers and over-the-road
buses to company operation centers, law enforcement agencies or emergency response personnel;
• Acquiring and installing equipment or systems that collect, store or exchange passenger and/or
driver information with established government databases for security purposes; and
• Implementing and operating established methodologies for screening passengers, their carry-on
baggage, and/or their checked baggage, for weapons and/or explosives.
Equipment and Capital Projects
Equipment and Capital Projects should address the Soft Targets/Crowded Places; Cybersecurity; and
Equipment/Capital Projects Priorities.
Equipment – Vehicle/Driver Security Enhancements
Vehicle Security Enhancements focus on vehicle disabling and anti-theft devices, real-time bus inventory
and inventory control, tracking, monitoring, alert and warning capabilities, and locating technologies.
Driver security enhancements focus on protection for the bus driver to prevent would-be terrorists from
immobilizing the driver and/or hijacking the bus. Applicants are discouraged from submitting projects
that propose the use of closed-circuit television (CCTV) alone as an on-board deterrent to terrorism.
Rather, any cameras should have the capability and protocols in place for incident-based real-time
monitoring. CCTV Systems that are primarily archival, and do not clearly specify the ability for live
monitoring in the Investment Justification (IJ) will not be funded.
IBSGP Appendix | May 2022 Page E-3
Capital Projects – Facility Security Enhancements
• Projects related to physical security enhancements at bus stations, or operator-owned facilities
including but not limited to lighting, security cameras, security screening equipment for people
and baggage, and access control (e.g., fences, gates, barriers);
• Projects related to cybersecurity of access control, sensors, security cameras, badge/ID readers,
Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems,
process monitors and controls, etc. or passenger/vehicle/cargo security screening equipment
support. Cybersecurity assessments are allowable; and
• Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff or
contractors/consultants may be hired to support security enhancement-related activities. Personnel
hiring, overtime, and backfill expenses are permitted under this grant only to the extent that such
expenses are for the allowable activities within the scope of the grant. Hiring of
contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R.
§§ 200.317-200.327.
Note: All Capital and Vehicle/Driver security enhancement projects that include cameras, video
surveillance, or alarm systems MUST either be live monitored 24/7 or have the capability for real-time
incident-based monitoring. CCTV Systems that are primarily archival and do not clearly specify the
ability for live monitoring in the IJ will not be funded.
Equipment Acquisition
IBSGP funds must comply with IB 426 and may be used for the following categories of equipment. A
comprehensive listing of allowable equipment categories and types is found in the Authorized Equipment
List (AEL). These costs include:
• Personal protection equipment;
• Explosive device mitigation and remediation equipment;
• Chemical, biological, radiological, nuclear, and explosive (CBRNE) operational search and
rescue equipment, or logistical support equipment;
• Interoperable emergency communications equipment;
• Detection equipment;
• Terrorism incident prevention equipment; and
• Physical security enhancement equipment.
Recipients may purchase equipment not listed on the AEL, but only if they first seek and obtain prior
approval from FEMA.
Unless otherwise noted, equipment must be certified as meeting required regulatory and DHS- adopted
standards to be eligible for purchase using these funds. Equipment must comply with the Occupational
Safety and Health Act requirement for certification of electrical equipment by a nationally recognized
testing laboratory and demonstrate compliance with relevant DHS-adopted standards through a supplier’s
declaration of conformity with appropriate supporting data and documentation per International
Organization for Standardization/International Electro-technical Commission (ISO/IEC) 17050, Parts One
and Two. Agencies must have all necessary certifications and licenses for the requested equipment, as
appropriate, prior to the request. In addition, recipients that are using IBSGP funds to support emergency
communications equipment activities must comply with the SAFECOM Guidance on Emergency
Communications Grants, including provisions on technical standards that ensure and enhance
interoperable communications. SAFECOM Guidance can be found at:
https://www.cisa.gov/safecom/funding.
IBSGP Appendix | May 2022 Page E-4
Cybersecurity Projects
IBSGP funds may be used for projects that enhance the cybersecurity of:
• Access controls; sensors; security cameras; badge/ID readers; ICS/SCADA systems; process
monitors and controls (such as firewalls, network segmentation, predictive security cloud, etc.).
CCTV Systems that are primarily archival, and do not clearly specify the ability for live
monitoring in the IJ will not be funded; and
• Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable).
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in
implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (“The
Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework
gathers existing international standards and practices to help organizations understand, communicate, and
manage their cyber risks. For organizations that do not know where to start with developing a
cybersecurity program, the Framework provides initial guidance. For organizations with more advanced
practices, the Framework offers a way to improve their programs, such as better communication with
their leadership and suppliers about management of cyber risks.
The Cybersecurity and Infrastructure Security Agency’s (CISA) Critical Infrastructure Cyber Community
C³ Voluntary Program also provides resources to critical infrastructure owners and operators to assist in
adoption of the Framework and managing cyber risks. Additional information on the Critical
Infrastructure Cyber Community C³ Voluntary Program can be found at http://www.cisa.gov/ccubedvp.
DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in
protecting U.S.-based public and private entities and combines key elements of capabilities under the
“Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the
Cybersecurity Framework. Specifically, ECS offers intrusion prevention and analysis services that help
U.S.-based companies and state, local, tribal, and territorial (SLTT) governments defend their computer
systems against unauthorized access, exploitation, and data exfiltration. ECS works by sourcing timely,
actionable cyber threat indicators from sensitive and classified Government Furnished Information (GFI).
DHS then shares those indicators with accredited Commercial Service Providers (CSPs). Those CSPs in
turn use the indicators to block certain types of malicious traffic from entering a company’s networks.
Groups interested in subscribing to ECS must contract directly with a CSP in order to receive services.
Please visit http://www.cisa.gov/enhanced-cybersecurity-services-ecs for a current list of ECS CSP points
of contact.
Capital (Construction) Projects Guidance
Recipients must obtain written approval from FEMA prior to the use of any IBSGP funds for construction
or renovation projects. When applying for construction funds, including communications towers, at the
time of application, recipients must submit evidence of approved zoning ordinances, architectural plans,
any other locally required planning permits. Additionally, recipients are required to submit a SF-424C and
budget detail citing the project costs and an SF-424D Form for standard assurances for the construction
project.
All Capital (Construction) projects require Environmental Planning and Historic Preservation (EHP)
review. Recipients are also encouraged to have completed as many steps as possible for a successful EHP
review in support of their proposal for funding (e.g., coordination with their State Historic Preservation
Office to identify potential historic preservation issues and to discuss the potential for project effects;
compliance with all state and EHP laws and requirements).
IBSGP Appendix | May 2022 Page E-5
Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in
DHS Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1 and FEMA Instruction
108-1-1, instances must also be identified to the FEMA HQ Preparedness Officer within the first six
months of the award. Completed EHP review materials for construction and communication tower
projects must be submitted no later than 12 months before the end of the period of performance. EHP
policy guidance and the EHP Screening Form, can be found online at: https://www.fema.gov/media-
library/assets/documents/90195. EHP review materials should be sent to gpdehpinfo@fema.gov.
Training and Awareness Campaigns
Training and Awareness Campaigns address the Soft Targets/Crowded Places; Cybersecurity; and
Training and Awareness Campaign Priorities.
Training
IBSGP funds may be used for the following training activities:
• Training Topics. Priority topics include active shooter training, security training for employees,
and public awareness/preparedness campaigns. The IJ narrative for Training should include:
o A course syllabus, curriculum, or topic plan identifying the proposed course material and
contents; and
o Provide the total cost of the training course, the number of participants, and the cost per
participant breakdown.
• Training Workshops. Grant funds may be used to plan and conduct training workshops or
conferences including costs related to planning, meeting space and other meeting costs,
facilitation costs, materials and supplies, travel, and training plan development.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be
hired to support training-related activities. Hiring of contractors/consultants must follow the
applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. The services of
contractors/consultants may also be procured in the design, development, conduct, and evaluation
of CBRNE training. Personnel hiring, overtime, and backfill expenses are permitted under this
grant only to the extent that such expenses are for the allowable activities within the scope of the
grant.
• Overtime and Backfill Costs. Overtime and backfill costs associated with the design,
development, and conduct of training are allowable expenses. Payment of overtime expenses will
be for work performed by recipient or subrecipient employees in excess of the established work
week related to the planning and conduct of the training project(s). Furthermore, overtime
payments and backfill costs associated with sending personnel to training are allowable. Grant
funds cannot be used for personnel or direct salary costs for employees to attend training sessions.
Recipients seeking to claim overtime or backfill costs will be required to submit verification.
Straight time costs are not eligible expenses.
• Travel. Domestic travel costs (e.g., airfare, mileage, per diem, hotel, etc.) are allowable as
expenses by employees who are on travel status for official business related to the planning and
conduct of the training project(s) or for attending courses. These costs must be in accordance with
applicable state law and regulations as well as the principles at 2 C.F.R. Part 200. International
travel is not an allowable cost under IBSGP.
• Supplies. Supplies are items that are expended or consumed during the course of the planning
and conduct of the training project(s) (e.g., copying paper, gloves, tape, and non-sterile masks).
• Funds Used to Develop, Deliver, and Evaluate Training, including costs related to
administering the training, planning, scheduling, facilities, materials and supplies, reproduction of
materials, and equipment are allowable expenses. Training should provide the opportunity to
demonstrate and validate skills learned, as well as to identify any gaps in these skills. Any
IBSGP Appendix | May 2022 Page E-6
training or training gaps, including those for individuals with disabilities or access and functional
needs, should be identified in the AAR/IP and addressed in the training cycle.
• Developing New Courses. Recipients are encouraged to use existing training rather than
developing new courses. When developing new courses, recipients are encouraged to apply the
Analysis, Design, Development, Implementation, and Evaluation (ADDIE) model of instructional
design. Information on FEMA-approved training can found at the following website
• Other Items. These costs include the rental of space/locations for planning and conducting
training, badges, etc. Recipients are encouraged to use free public space/locations, whenever
available, prior to the rental of space/locations.
Awareness Campaigns
IBSGP funds may be used for the development and implementation of awareness campaigns to raise
public awareness of indicators of terrorism and terrorism-related crime, and associated efforts to increase
the sharing of information with public and private sector partners, including nonprofit organizations. DHS
currently sponsors or supports a number of awareness campaigns. Please review materials, strategies, and
resources at https://www.dhs.gov/dhs-campaigns before embarking on the development of an awareness
campaign for your local constituencies and stakeholders.
Note: DHS requires that all public and private sector partners wanting to implement and/or expand the
DHS “If You See Something, Say Something®” campaign using grant funds work directly with the DHS
Office of Partnership and Engagement (OPE). This will help ensure that the awareness materials (e.g.,
videos, posters, trifolds, etc.) remain consistent with the Department’s messaging and strategy for the
campaign and compliant with the initiative's trademark, which is licensed to DHS by the New York
Metropolitan Transportation Authority. Coordination with OPE, through the Campaign’s Office
(seesay@hq.dhs.gov), must be facilitated by the FEMA HQ Preparedness Officer.
Exercises
Exercise activities should address the Soft Targets/Crowded Places; Cybersecurity; and Exercises
Priorities.
IBSGP funds may be used for the following exercise activities:
• Funds Used to Design, Develop, Conduct, and Evaluate an Exercise. This includes costs
related to planning, meeting space, and other meeting costs, facilitation costs, materials and
supplies, travel, and documentation. Exercises afford organizations the opportunity to validate
plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets
in a controlled, low risk setting. Any shortcoming or gap identified, including those for children
and individuals with disabilities or access and functional needs, should be identified in an
effective corrective action program that includes development of improvement plans that are
dynamic documents, with corrective actions continually monitored and implemented as part of
improving preparedness through the exercise cycle.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be
hired to support exercise-related activities. The services of contractor/consultant staff may be
procured to support exercise-related activities. The services of contractors/consultants may also
be procured to support the design, development, conduct, and evaluation of terrorism exercises.
Hiring of contractors/consultants must follow the applicable federal procurement requirements at
2 C.F.R. §§ 200.317-200.327.
• Overtime and Backfill Costs. Overtime and backfill costs associated with the design,
development, and conduct of terrorism exercises are allowable expenses. Payment of overtime
expenses will be for work performed in excess of the established work week related to the
IBSGP Appendix | May 2022 Page E-7
planning and conduct of the exercise project(s). Further, overtime payments and backfill costs
associated with sending personnel to exercises are allowable, provided that the event being
attended is a DHS sponsored exercise. For positions not funded by the grant award, grant funds
cannot be used for personnel or straight salary costs for employees to attend exercises, meaning
straight time costs for non-grant funded employees to attend exercise are not allowable. Instead,
for positions not funded by the grant award, only overtime and backfill costs will be allowable for
those employees to attend exercises. Recipients seeking to claim overtime or backfill costs will be
required to submit verification.
• Travel. Domestic travel costs (e.g., airfare, mileage, per diem, hotel, etc.) are allowable as
expenses by employees who are on travel status for official business related to the planning and
conduct of the exercise project(s). International travel is not allowable under this program.
• Supplies. Supplies are items that are expended or consumed during the course of the planning
and conduct of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective
equipment).
• Other Items. These costs include the rental of space/locations for exercise planning and
executing, rental of equipment, etc. Recipients are encouraged to use free public
space/locations/facilities, whenever available, prior to the rental of space/locations/facilities.
These also include costs that may be associated with inclusive practices and the provision of
reasonable accommodations and modifications to provide full access for children and adults with
disabilities.
Management and Administration (M&A)
Management and administration costs are allowed under this program. M&A costs are activities directly
related to managing and administering the award. Recipients may use up to 5% of the amount of the
award for their M&A.
FY 2022 IBSGP funds may be used for the following M&A costs:
• Hiring of full-time or part-time staff including contractors and consultants, to execute the
following: o Management of the current fiscal year IBSGP award; and o Design and implementation of the current fiscal year IBSGP submission meeting
compliance with reporting/data collection requirements, including data calls.
• Information collection and processing necessary to respond to FEMA data calls; and
• Domestic travel expenses related to IBSGP grant administration.
Indirect Costs (Facilities and Administration [F&A])
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
IBSGP Appendix | May 2022 Page E-8
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
Unallowable Costs
Specific unallowable costs include:
• Grant funds must comply with IB 426 and may not be used for the purchase of the following
equipment: firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft, vessels,
or vehicles of any kind with weapons installed;
• General-use facility expenditures, to include, but not limited to ordinary facility maintenance,
contracts for maintenance, and specifically backup or emergency generators;
• General vehicle maintenance, service contracts, or warranties. This is different from maintenance
and sustainment costs that are allowable, but only for projects funded under a grant award. For
projects or equipment not funded by the grant award, general maintenance, service contracts, and
warranties are not allowable;
• Expenditures for items such as general-use software (word processing, spreadsheet, graphics,
etc.), general-use computers and related equipment (other than for allowable M&A activities, or
otherwise associated preparedness or response functions), general-use vehicles, licensing fees,
recurring operating costs (e.g., cell phone services, maintenance contracts);
• Organizational operating expenses;
• Personnel costs, to include, but not limited to, overtime and backfill (except as detailed above);
• Activities unrelated to the completion and implementation of the IBSGP;
• Other indirect costs (meaning property purchase, depreciation, or amortization expenses);
• Initiatives in which federal agencies are the beneficiary or that enhance federal property;
• Initiatives which study technology development;
• Proof-of-concept initiatives;
• Initiatives that duplicate capabilities being provided by the Federal Government;
• Other items not in accordance with the AEL, in accordance with IB 426, or not previously listed
as allowable costs; and
• Pre-award costs are not allowable and will not be approved, with the exception of costs resulting
from pre-award grant writing services provided by an independent contractor that shall not
exceed $1,500, as detailed in “Pre-Award Costs” above and in the IBSGP NOFO.
Other Allowable Costs
Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses, and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
IBSGP Appendix | May 2022 Page E-9
Grant funds are intended to support the National Preparedness Goal (the Goal) and fund projects that
build and sustain the core capabilities necessary to prevent, protect against, mitigate the effects of,
respond to, and recover from those threats that pose the greatest risk to the security of the Nation. In order
to provide recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State
Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for
the expansion of eligible maintenance and sustainment costs which must be in (1) direct support of
existing capabilities; (2) must be an otherwise allowable expenditure under the applicable grant program,
and (3) be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally,
eligible costs may also be in support of equipment, training, and critical resources that have previously
been purchased with either federal grant or any other source of funding other than FEMA preparedness
grant program dollars.
Bonds
Financial markets are not always predictable, and commercial suppliers are not always reliable; but there
are options to provide resource contingencies to support an IBSGP award.
• Prepayment Bond: Prepayment Bonds provide a measure of economic security for an
organization that is going to advance funds to a vendor(s). The prepayment bond generally may
be obtained through the vendor or bank. The prepayment bond protects funds in the event a
vendor fails to perform (e.g., not finishing/delivering contracted service/equipment, or going out
of business). Prepayment bonds are chargeable to an award.
o Encouraged Prepayment Bond: Recipients are strongly recommended, but not
required, to obtain a prepayment bond for awarded acquisition activities that exceed the
Simplified Acquisition Threshold (SAT) (currently $250,000, but the applicable dollar
threshold will be the SAT amount in place at the time of procurement) when recipients
are contractually required to advance a down payment and when such advances contain
no federal funds (only local funds).
o Required Prepayment Bond: Per 2 C.F.R. § 200.304(b), recipients are required to
obtain a prepayment bond for awarded acquisition activities that exceed the SAT; a
prepayment bond is required when recipients are contractually required to advance a
down payment and when such advances contain only federal funds or a combination of
federal and local funds.
• Fidelity Bond: Reasonable costs of fidelity bonds (or like insurance as provided for by applicable
state or tribal laws) covering the maximum amount of IBSGP funds the officer, official, or
employee handles at any given time for all personnel who disburse or approve disbursement of
IBSGP funds may be allowable if required by the terms and conditions of the award or if
generally required by the tribe in its generally operations. If a fidelity bond is required by a
recipient in its general operations, those costs must be charged as indirect costs. See 2 C.F.R. §
200.427.
Encouraged Use of Certain Products Produced in the United States
Pursuant to Executive Order 13858 “Strengthening Buy-American Preferences for Infrastructure
Projects,” FEMA encourages non-federal entities under this grant program to use, to the greatest extent
practicable and consistent with the law, iron and aluminum as well as steel, cement, and other
manufactured products produced in the United States, in projects funded by an award under this grant
program affecting surface transportation, including roadways, bridges, railroads, and transit; aviation;
ports, including navigational channels; water resources projects; energy production, generation, and
storage, including from fossil-fuels, renewable, nuclear, and hydroelectric sources; electricity
transmission; gas, oil, and propane storage and transmission; electric, oil, natural gas, and propane
distribution systems; broadband internet; pipelines; stormwater and sewer infrastructure; drinking water
IBSGP Appendix | May 2022 Page E-10
infrastructure; and cybersecurity. Notwithstanding this encouragement, non-federal entities must take care
that all procurements and contract actions are consistent with law, this Manual and applicable appendices,
the grant program’s NOFO, and the federal procurement standards at 2 C.F.R. §§ 200.317-200.326.
IPR Appendix | May 2022 Page F-1
Program Appendix F:
Intercity Passenger Rail (IPR) Program
As a reminder, while this appendix contains IPR-specific information and requirements, the main content
of this Manual (non-appendix information) contains important information relevant to all preparedness
grant programs, including the IPR. Please be sure to read the main content of this Manual in addition to
the program-specific appendices.
The IPR grant recipient may only use IPR grant funds for the purposes set forth in the Notice of Funding
Opportunity (NOFO), and all investments must be consistent with the statutory authority for the award.
Grant funds may not be used for matching funds for other federal awards, lobbying, or intervention in
federal regulatory or adjudicatory proceedings. In addition, federal funds may not be used to sue the
Federal Government or any other government entity.
IPR Funding Guidelines
Costs charged to a an IPR award must be consistent with the uniform administrative requirements and
audit requirements for federal awards, located at 2 C.F.R. Part 200, Subparts A-D and F. For more
information on 2 C.F.R. Part 200, please see Information Bulletin (IB) 400 regarding FEMA’s
implementation of these provisions prior to the recent 2020 revisions. For information on the recent
revisions to these regulations, see 2 CFR Grants Management Policy Updates | FEMA.gov and
www.performance.gov/CAP/grants/. Costs charged to an IPR award must also be consistent with the cost
principles in the Federal Acquisition Regulation (FAR) Part 31.2 in lieu of 2 C.F.R. Part 200, Subpart E.
Any conflicts between FAR 31.2 and 2 C.F.R. Part 200, Subpart E shall be resolved in favor of the
applicable provision in FAR 31.2.
IPR Priorities
See the annual IPR NOFO.
Security Plan Requirements
The following information regarding security plan requirements is provided in 6 U.S.C. § 1134(c)(2):
Security plans should include the following, as appropriate:
• A prioritized list of all items included in the public transportation agency’s security assessment
that have not yet been addressed;
• A detailed list of any additional capital and operational improvements identified by DHS or the
public transportation agency and a certification of the public transportation agency’s technical
capacity for operating and maintaining any security equipment that may be identified in such list;
• Specific procedures to be implemented or used by the public transportation agency in response to
a terrorist attack, including evacuation and passenger communication plans and appropriate
evacuation and communication measures for the elderly and individuals with disabilities;
• A coordinated response plan that establishes procedures for appropriate interaction with state and
local law enforcement agencies, emergency responders, and federal officials in order to
IPR Appendix | May 2022 Page F-2
coordinate security measures and plans for response in the event of a terrorist attack or other
major incident;
• A strategy and timeline for conducting training under 49 C.F.R. § 1570.109(b) and 49 C.F.R. Part
1580;
• Plans for providing redundant and other appropriate backup systems necessary to ensure the
continued operation of critical elements of the public transportation system in the event of a
terrorist attack or other major incident;
• Plans for providing service capabilities throughout the system in the event of a terrorist attack or
other major incident in the city or region which the public transportation system serves;
• Methods to mitigate damage within a public transportation system in case of an attack on the
system, including a plan for communication and coordination with emergency responders; and
• Other actions or procedures as the Secretary of Homeland Security determines are appropriate to
address the security of the system.
Allowable Costs
Specific investments made in support of the funding priorities discussed in the annual IPR NOFO
generally fall into one of the following six allowable expense categories:
1) Planning;
2) Operational Activities;
3) Equipment and Capital Projects;
4) Training and Awareness Campaigns;
5) Exercises; and
6) Management and Administration.
The following provides guidance on allowable costs within each of these areas.
Planning
Planning activities that address the Soft Targets/Crowded Places Priority.
IPR funds may be used for the following types of planning activities:
• Development and enhancement of system-wide security risk management plans that ensure the
continuity of essential functions, to include cyber;
• Development or further strengthening of continuity plans, response plans, station action plans,
risk assessments, and asset-specific remediation plans;
• Development or further strengthening of security assessments, including multi-agency and multi-
jurisdictional partnerships and conferences to facilitate planning activities;
• Hiring of full or part-time staff and contractors or consultants to assist with planning activities
only to the extent that such expenses are for the allowable activities within the scope of this grant
(not for the purpose of hiring public safety personnel); hiring of contractors/consultants must
follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327
• Materials required to conduct planning activities;
• Conducting risk and resilience assessments on increasingly connected cyber and physical
systems, on which security depends, using the Infrastructure Resilience Planning Framework and
related CISA resources;
• Planning activities related to alert and warning capabilities; and
• Other project planning activities, with prior approval from FEMA.
IPR Appendix | May 2022 Page F-3
Operational Activities
Operational Activities that address the Soft Targets/Crowded Places Priority.
FEMA encourages applicants to develop innovative operational approaches to enhance the security of
transit systems. Projects that use visible, unpredictable deterrence, including operational packages dealing
with explosive detection canine teams, mobile screening teams, and anti-terrorism teams, directly support
enhancing the protection of soft targets and crowded places. Implementation of one of the three
Operational Package (OPack) models discussed below complements existing security systems and
provides an appropriate, practical, and cost-effective means of protecting assets.
Agencies may submit IJs to fund transit security police forces/law enforcement providers for patrols and
activities on overtime, such as directed patrols, additional canine teams, mobile screening teams, or anti-
terrorism team patrols. These activities must be dedicated to the transit environment and must be anti-
terrorism in nature. Agencies must identify the type of activity, length of operation (hours), number of
personnel, and cost based on length of operation and personnel. Agencies should also provide a risk-based
justification for the request, including linkage to a known event, such as hosting a significant regional
sporting or political event; or a period of heightened awareness, such as a national holiday. Three OPack
types have been developed to support operational activities and are available for funding under the IPR:
• Explosives Detection Canine Teams (EDCTs). When combined with the existing capability of a
transit security/police force, the added value provided through the addition of an EDCT is
significant. EDCTs are a proven, reliable resource to detect explosives and are a key component
in a balanced counter-sabotage program. The TSGP will provide funds to establish dedicated
security/police force canine teams. Each canine team will be composed of one dog and one
handler.
• Anti-Terrorism Teams (ATTs). The ATT capability provided through TSGP funding is for
uniformed, dedicated transit patrols on a normal operational basis, rather than using teams only
for a surge capacity as provided by FEMA in the past. ATTs do not supersede other local transit
security forces; rather, they augment current capabilities. Each ATT will consist of four
individuals, including two overt elements (e.g., uniformed transit sector law enforcement officer,
canine team, mobile explosive screeners), and two discreet observer elements.
• Mobile Explosive Screening Teams (MESTs). The MEST OPack will allow recipients the
flexibility to deploy combinations of certified explosive ordinance technicians with mobile
explosive screening technologies, including during local National Special Security Events. This
screening technology will be coupled with mobile explosive screening technologies. Each MEST
should have a minimum of two members and one mobile explosive screening apparatus.
Note: Funds for canine teams may not be used to fund drug detection and apprehension technique
training. Only explosives detection training for the canine teams will be funded.
Five-Year Security Capital Plan and Operational Sustainment
Applicant requests for OPack funding must include the submission of a Five-Year Security Capital
and Operational Sustainment Plan in ND Grants. This plan must include how the agency proposes to
implement capital projects and demonstrate how the agency will sustain the operational investments
(including officers hired with federal funding) and capabilities after grant funding has been expended.
Requests for OPacks will not be funded if the applicant does not have and submit a Security Capital
and Operational Sustainment Plan.
IPR Appendix | May 2022 Page F-4
Funding Availability for OPacks
OPacks have the potential to be funded for up to a 36-month period from the award date. The monetary
figures presented below are stated in terms of cost per period of performance (which indicates
actual/complete funding for a 36-month period). Additionally, any OPack costs after the period of
performance (including expenses related to the maintenance, personnel, equipment, etc.) are the
responsibility of the applicable transit system. Additional funding may be applied for in future grant
cycles to maintain this operational capability, but future funding is not guaranteed and requires approval.
If these positions are not sustained, the public transportation agency may not be eligible for this personnel
support in the future. The table below identifies the maximum funding available for the different OPack
types.
Available Funding for OPacks
Operational Package Maximum Funding per Year
(12 months)
Maximum Funding per Period of
Performance (36 months)
EDCT $150,000 per team $450,000 per team
ATT $500,000 per team $1,500,000 per team
MEST $600,000 per team $1,800,000 per team
OPack Requirements
IPR OPack funds may be used for new positions or to sustain existing capabilities/programs (e.g., canine
teams) already supported by the recipient. Applicants pursuing both new OPacks and sustainment funding
for existing OPacks must indicate in their IJs which funding the higher priority for their agency is.
Additionally, applicants must provide the number of existing teams (EDCT, ATT, and MEST) already in
place, regardless of how they are funded. The below table identifies specific OPack requirements.
OPack Requirements
Operational
Requirements
EDCT Please refer to the pages below for detailed information regarding EDCTs
under the IPR
ATT
Specific for the Canine Team within the ATT:
• Each canine team, composed of one dog and one handler, must be certified
by an appropriate, qualified organization
• Canines should receive an initial basic training course and also weekly
maintenance training sessions thereafter to maintain the certification
• The basic training averages 10 weeks for the team, with weekly training and
daily exercising (comparable training and certification standards, such as
those promulgated by the Transportation Security Administration (TSA)
Explosive Detection Canine Program), the National Police Canine
Association (NPCA), the United States Police Canine Association
(USPCA), or the International Explosive Detection Dog Association
(IEDDA) may be used to meet this requirement
• The individuals hired for the covert and overt elements must be properly
trained law enforcement officers
• Certifications should be on file with the recipient and must be made
available to FEMA upon request
MEST Certifications should be on file with the recipient and must be made available
to FEMA upon request
IPR Appendix | May 2022 Page F-5
Allowable Expenses for OPacks
The table below identifies allowable expenses for the various OPacks. Please see the accompanying notes
for clarification of certain allowable costs.
Allowable Expenses for OPacks
Operational Package Salary and Fringe Benefits Training and Certification Equipment Costs Purchase and Train a Canine Canine Costsb 1) EDCTa c
2) ATT
3) MEST d
a Travel costs associated with training for personnel, handlers, and canines are allowable
b Canine costs include but are not limited to a canine’s veterinary, housing, and feeding costs
c One type of allowable training is training specific to the detection of common explosives odors
d Equipment and other costs can include but are not limited to explosives detection; stainless steel search tables;
consumables such as gloves, swabs, and alcohol; and land mobile radios
Specific Guidance on EDCT
EDCT Certification
Each EDCT, composed of one dog and one handler, must be certified by an appropriate, qualified
organization. TSA-certified EDCTs will meet or exceed certification standards set by the TSA National
Explosives Detection Canine Team Program (NEDCTP). Recipient EDCTs that do not participate in the
NEDCTP will be required to certify annually under their respective agency, local, and state regulations.
The recipient will maintain certification, utilization, and training data to show compliance in meeting or
exceeding those guidelines set forth by the Scientific Working Group on Dog and Orthogonal Detection
Guidelines (SWGDOG), as of September 14, 2007, in addition to the requirements set forth in the NOFO.
EDCT Submission Requirements
1) The recipient will ensure that a written security procedure plan exists for the safekeeping of all
explosive training aids, including safe transportation. The recipient will document the removal,
use, and return of explosive training aids used during training exercises or for any other reason.
The plan and all documentation must be made available to FEMA upon request;
2) The recipient will comply with requirements for the proper storage, handling, and transportation
of all explosive training aids in accordance with the Bureau of Alcohol, Tobacco, Firearms and
Explosives’ Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law and Regulation;
3) The recipient will ensure that certified EDCTs are available to respond to situations 24 hours a
day, 7 days per week on an on-duty or off-duty on-call basis. If IPR-funded EDCTs are not
available, other, non-IPR funded EDCTs may be utilized for this response. The intent is to
provide maximum coverage during peak operating hours and to maintain the ability to promptly
respond to threats that affect public safety or mass transit operations;
4) EDCTs under this grant are single purpose and will be trained to detect “live” explosives only,
not “simulated” explosives. EDCTs must not have received previous training to detect any other
substances;
IPR Appendix | May 2022 Page F-6
5) The recipient will ensure that each EDCT receives on-site proficiency training at a minimum of 4
hours per week per duty cycle. This training shall include, but not be limited to, mass transit
passenger cars, terminals/platforms, luggage, freight/warehouses, and vehicles. Complete,
detailed, and accurate training records must be maintained for all proficiency training conducted
by each EDCT. These records must be made available to FEMA upon request;
6) The recipient will conduct appropriate training or other canine activities, within view of the
public, to increase public awareness of EDCTs and provide a noticeable deterrent to acts which
affect public safety or mass transit operations. The recipient will also ensure that such activities
include, over a period of time, a presence in operational areas of the mass transit system during
peak and off-peak hours. The recipient agrees that EDCTs will be utilized in the field at least 80%
of their duty time, annually;
7) The recipient will provide safe and sanitary kennel facilities for program canines, and these costs
may be allowable with prior approval by FEMA. This applies to kenneling canines at a mass
transit system, handlers’ residences, or commercial boarding facilities. Canines must not be left in
makeshift accommodations or without proper supervision, protection, and care. The recipient will
ensure that canines are transported on-duty and off-duty in vehicles configured with adequate
temperature control, padding, and screening to ensure proper health, safety, and security; and
8) The recipient will ensure that adequate routine and emergency veterinary care are provided for all
canines.
Note: FEMA reserves the right to conduct an on-site operational and record review upon 48-hour notice
to ensure compliance with applicable federal regulations.
Equipment and Capital Projects
Equipment and Capital Projects that address the Soft Targets/Crowded Places and Cybersecurity
Priorities.
Priority projects include Top Transit Asset List (TTAL) risk remediation and protection of other high-
risk, high-consequence areas or systems that have been identified through system-wide risk assessments:
• Projects related to physical security enhancements at rail and bus stations in Urban Area Security
Initiative (UASI) jurisdictions, including security cameras, security screening equipment for
people and baggage, and access control (e.g., fences, gates, barriers, etc.); and
• Projects related to cybersecurity of access control, sensors, security cameras, badge/ID readers,
Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems,
process monitors and controls, etc. or passenger/vehicle/cargo security screening equipment
support. Cybersecurity assessments are allowable.
Equipment Acquisition
IPR funds may be used for the following categories of equipment. A comprehensive listing of allowable
equipment categories and types is found in the Authorized Equipment List (AEL). These costs include:
• Personal protection equipment;
• Explosive device mitigation and remediation equipment;
• Chemical, biological, radiological, nuclear, and high explosive (CBRNE) operational search and
rescue equipment, logistical support equipment, reference materials, or incident response
vehicles;
• Interoperable communications equipment, including for alert and warning capabilities;
IPR Appendix | May 2022 Page F-7
• Components or systems needed to address flaws in the computerized systems that control
generators, switching stations, and electrical substations as well as other threats to infrastructure
critical to the U.S. economy;
• Detection Equipment;
• Power equipment;
• Terrorism incident prevention equipment; and
• Physical security enhancement equipment.
Recipients may purchase equipment not listed on the AEL, but only if they first seek and obtain prior
approval from FEMA.
Unless otherwise noted, equipment must be certified as meeting required regulatory and FEMA- adopted
standards to be eligible for purchase using IPR funds. Equipment must comply with the Occupational
Safety and Health Act requirement for certification of electrical equipment by a nationally recognized
testing laboratory and demonstrate compliance with relevant FEMA-adopted standards through a
supplier’s declaration of conformity with appropriate supporting data and documentation per International
Organization for Standardization/International Electro-technical Commission (ISO/IEC) 17050, Parts One
and Two. The recipient must have all necessary certifications and licenses for the requested equipment, as
appropriate, prior its purchase. In addition, if the recipient is using IPR funds to support emergency
communications equipment activities must comply with the SAFECOM Guidance on Emergency
Communications Grants, including provisions on technical standards that ensure and enhance
interoperable communications. This SAFECOM Guidance can be found at:
https://www.cisa.gov/safecom/funding.
Requirements for Small Unmanned Aircraft Systems
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and also include a description of the policies and procedures in place to safeguard individuals’
privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or otherwise use the
sUAS equipment. SUAS policies are not required at the time of application but must be received and
approved by FEMA prior to obligating IPR funds. All grant-funded procurements must be executed in a
manner compliant with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. For recipients
that use IPR funds for sUAS, FEMA advises that there is a general privacy concern related to the use of
this equipment if the data the devices collect is transmitted to servers not under the control of the
operator. It has been reported that some manufacturers of sUAS encrypt data and send that data to servers
outside the United States. The U.S. Department of Homeland Security’s Privacy Office suggests the
recipient fully explore data transmission and storage issues with vendors to reduce the possibility of data
breaches.
Additionally, the Joint Explanatory Statement (JES) accompanying the FY 2022 DHS Appropriations
further requires recipients to certify they have reviewed the Industry Alert on Chinese Manufactured
Unmanned Aircraft Systems, and completed a risk assessment that considers the proposed use of foreign-
made sUAS to ascertain potential risks (e.g., privacy, data breaches, cybersecurity, etc.) related to foreign-
made versus domestic sUAS.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA was alerted you of an advisory guidance document issued by DHS, the
Department of Justice, the Federal Aviation Administration, and the Federal Communications
Commission: https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-
technologies. The purpose of the advisory guidance document is to help non-federal public and private
IPR Appendix | May 2022 Page F-8
entities better understand the federal laws and regulations that may apply to the use of capabilities to
detect and mitigate threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
representations of the systems’ legality or functionality. Please also see the DHS press release on this
topic for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-
technology-detect-and-mitigate-unmanned-aircraft.
Cybersecurity Projects
IPR funds may be used for projects that enhance the cybersecurity of:
• Access controls, sensors; security cameras, badge/ID readers, ICS/SCADA systems, process
monitors and controls (such as firewalls, network segmentation, predictive security cloud, etc.);
and
• Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable).
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in
implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the
“Framework”), developed by the National Institute of Standards and Technology (NIST). The Framework
gathers existing international standards and practices to help organizations understand, communicate, and
manage their cyber risks. For organizations that do not know where to start with developing a
cybersecurity program, the Framework provides initial guidance. For organizations with more advanced
practices, the Framework offers ways to improve their programs, such as through better communication
with their leadership and suppliers about management of cyber risks.
The Cybersecurity and Infrastructure Security Agency’s (CISA) Critical Infrastructure Cyber Community
C³ Voluntary Program also provides resources to critical infrastructure owners and operators to assist in
adoption of the Framework and managing cyber risks. Additional information on the Critical
Infrastructure Cyber Community C³ Voluntary Program can be found at www.cisa.gov/ccubedvp.
DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in
protecting U.S.-based public and private entities and combines key elements of capabilities under the
“Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the
Framework. Specifically, ECS offers intrusion prevention and analysis services that help U.S.-based
companies and SLTT governments defend their computer systems against unauthorized access,
exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat indicators from
sensitive and classified Government Furnished Information. DHS then shares those indicators with
accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to block certain
types of malicious traffic from entering a company’s networks. Groups interested in subscribing to ECS
must contract directly with a CSP in order to receive services. Please visit http://www.cisa.gov/enhanced-
cybersecurity-services-ecs for a current list of ECS CSP points of contact.
IPR Appendix | May 2022 Page F-9
Capital (Construction) Projects Guidance
The recipient must obtain written approval from FEMA prior to the use of any IPR funds for construction
or renovation projects. When applying for construction funds, including communications towers, the
recipient must submit evidence of approved zoning ordinances, architectural plans, any other locally
required planning permits. Additionally, the recipient is required to submit a SF-424C and budget detail
citing the project costs and an SF-424D Form for standard assurances for the construction project.
All construction or renovation projects require Environmental Planning and Historic Preservation (EHP)
review. The recipient is also encouraged to have completed as many steps as possible for a successful
EHP review in support of their proposal for funding (e.g., coordination with the relevant Historic
Preservation Office to identify potential historic preservation issues and to discuss the potential for project
effects; compliance with all state and local EHP laws and requirements).
Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in
DHS Instruction Manual 023-01-001-01, Revision 01, EHP Directive and Instruction, FEMA Directive
108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness Officer
within the first six months of the award, regardless of the length of the period of performance. Completed
EHP review materials for construction and communication tower projects must be submitted no later than
12 months before the end of the period of performance. EHP policy guidance and the EHP Screening
Form, can be found online at: https://www.fema.gov/media-library/assets/documents/90195. EHP review
materials should be sent to gpdehpinfo@fema.dhs.gov.
If the recipient uses funds for construction projects, it must comply with the Davis-Bacon Act (codified as
amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 1163(h) (cross-referencing 49 U.S.C. § 24312,
which cross-references Davis-Bacon). It must ensure that its contractors or subcontractors for
construction projects pay workers no less than the prevailing wages for laborers and mechanics employed
on projects of a character similar to the contract work in the civil subdivision of the state in which the
work is to be performed. Additional information regarding compliance with the Davis-Bacon Act,
including the Department of Labor (DOL) wage determinations, is available at
https://www.dol.gov/whd/govcontracts/dbra.htm.
Training and Awareness Campaigns
Training and Awareness Campaigns that address the Soft Targets/Crowded Places and Cybersecurity
Priorities.
Training
IPR funds may be used for the following training activities:
• Training Topics. Priority topics include active shooter training, security training for employees,
and public awareness/preparedness campaigns.
• Training Workshops. Grant funds may be used to plan and conduct training workshops,
including costs related to planning, meeting space and other meeting costs, facilitation costs,
materials and supplies, travel, and training plan development. The recipient is strongly
encouraged to use free public space, locations, or facilities, whenever available, prior to the rental
of space, locations, or facilities. Training should provide the opportunity to demonstrate and
validate skills learned as well as to identify any gaps in these skills. Any training or training gaps,
including those for children and individuals with disabilities or access and functional needs,
should be identified in an After-Action Report/Improvement Plan (AAR/IP) and addressed in the
training cycle.
IPR Appendix | May 2022 Page F-10
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff or
contractors/consultants may be hired to support training-related activities. Reimbursement of
these costs should conform with the policies of recipient, as well as any applicable federal and
FEMA policies, rules, and regulations. Hiring of contractors/consultants must follow the
applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. Dual compensation
is unallowable, in other words, an employee of a unit of government may not receive
compensation from their unit or agency of government and from an award for a single period of
time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both activities. Personnel
hiring, overtime, and backfill expenses are permitted under this grant only to the extent that such
expenses are for allowable activities within the scope of the grant.
• Overtime and Backfill Costs. The entire amount of overtime costs, including payments related
to backfilling personnel, that are the direct result of attendance at FEMA and approved training
courses and programs are allowable. Reimbursement of these costs should follow the policies of
the recipient, as well as any applicable federal and FEMA policies, rules, and regulations. state.
Dual compensation is never allowable.
• Travel. Domestic travel costs (e.g., airfare, mileage, per diem, and hotel) are allowable as
expenses by employees who are on travel status for official business related, approved training,
subject to the restrictions at 2 C.F.R. Part 200. International travel is not an allowable expense.
• Supplies. Supplies, items that are expended or consumed during the course of the planning and
conduct of the training project(s) (e.g., gloves and non-sterile masks), are allowable expenses.
• Funds Used to Develop, Deliver, and Evaluate Training. Funds used to develop, deliver, and
evaluate training, including costs related to administering the training, planning, scheduling,
facilities, materials and supplies, reproduction of materials, and equipment are allowable
expenses. Training should provide the opportunity to demonstrate and validate skills learned as
well as to identify any gaps in these skills. Any training or training gaps, including those for
children and individuals with disabilities or access and functional needs, should be identified in
the AAR/IP and addressed in the training cycle.
Recipients are encouraged to use existing training rather than developing new courses. When developing
new courses, recipients are encouraged to apply the Analysis, Design, Development, Implementation, and
Evaluation (ADDIE) model of instructional design. Information on FEMA-approved training can found at
http://www.firstrespondertraining.gov/.
Awareness Campaigns
IPR funds may be used for the development and implementation of awareness campaigns to raise public
awareness of indicators of terrorism and terrorism-related crime and for associated efforts to increase the
sharing of information with public and private sector partners, including nonprofit organizations. DHS
currently sponsors or supports a number of awareness campaigns. Please review materials, strategies, and
resources at https://www.dhs.gov/dhs-campaigns before embarking on the development of an awareness
campaign for local constituencies and stakeholders.
Note: DHS requires that all public and private sector partners wanting to implement and/or expand the
DHS “If You See Something, Say Something®” campaign (“campaign”) using grant funds work directly
with the DHS Office of Partnership and Engagement (OPE). This will help ensure that the awareness
materials (e.g., videos, posters, trifolds, etc.) remain consistent with DHS’s messaging and strategy for the
campaign and compliant with the initiative’s trademark, which is licensed to DHS by the New York
Metropolitan Transportation Authority. Coordination with OPE, through the campaign’s office
(seesay@hq.dhs.gov), must be facilitated by the FEMA Preparedness Officer.
IPR Appendix | May 2022 Page F-11
Exercises
Exercise activities that address the Soft Targets/Crowded Places and Cybersecurity Priorities.
IPR funds may be used for the following exercise activities:
• Funds Used to Design, Develop, Conduct and Evaluate an Exercise. This includes costs
related to planning, meeting space and other meeting costs, facilitation costs, materials and
supplies, travel, and documentation. Exercises afford organizations the opportunity to validate
plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets
in a controlled, low risk setting. Any shortcomings or gaps identified, including those for children
and individuals with disabilities or access and functional needs, should be identified in an
effective corrective action program that includes development of improvement plans that are
dynamic documents, with corrective actions continually monitored and implemented as part of
improving preparedness through the exercise cycle.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be
hired to support exercise-related activities. Reimbursement of these costs should conform with
the policies of the recipient, as well as any applicable federal and FEMA policies, rules, and
regulations. Dual compensation is not allowable, meaning, in other words, that an employee of a
unit of government may not receive compensation from their unit or agency of government and
from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though their work
may benefit both entities. Personnel hiring, overtime, and backfill expenses are permitted under
this grant only to the extent that such expenses are for the allowable activities within the scope of
the grant. The recipient must follow all applicable procurement regulations at 2 C.F.R. Part 200
when procuring contractor services.
• Overtime and Backfill Costs. The entire amount of overtime costs, including payments related
to backfilling personnel, which are the direct result of time spent on designing, developing, and
conducting exercises are allowable expenses. These costs are allowed only to the extent the
payment for such services is in accordance with the policies of the recipient and has the approval
of the awarding agency, if applicable. Dual compensation is never allowable.
• Travel. Domestic travel costs are allowable as expenses by employees who are on travel status
for official business related to the planning and conduct of exercise project(s), subject to the
restrictions at 2 C.F.R. Part 200. International travel costs are not allowable expenses.
• Supplies. Supplies are items that are expended or consumed during the course of the planning
and conduct of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective
equipment).
• Other Items. These costs include the rental of space or locations for exercise planning and
executing, rental of equipment, etc. The recipient is encouraged to use free public space,
locations, or facilities, whenever available, prior to the rental of space, locations, or facilities.
These also include costs that may be associated with inclusive practices and the provision of
reasonable accommodations and modifications to provide full access for children and adults with
disabilities.
Management and Administration (M&A)
Management and administration costs are allowed under this program. M&A costs are activities directly
related to managing and administering the award. The recipient may use up to 5% of the amount of the
award for its M&A costs.
Fiscal year 2022 IPR funds may be used for the following M&A costs:
IPR Appendix | May 2022 Page F-12
• Hiring of full-time or part-time staff, including contractors and consultants, to execute the
following:
o Management of the current fiscal year IPR Award; and
o Design and implementation of the current fiscal year IPR submission meeting compliance
with reporting/data collection requirements, including data calls.
• Information collection and processing necessary to respond to FEMA data calls;
• Domestic travel expenses related to IPR grant administration, in compliance with the Super
Circular, 2 C.F.R. Part 200; and
• Acquisition of authorized office equipment, including personal computers or laptops for IPR
M&A purposes.
Indirect Costs
Indirect costs are allowable under this program as described in the Federal Acquisition Regulation (FAR).
Unallowable Costs
Specific unallowable costs include:
• Grant funds must comply with IB 426 and may not be used for the purchase of the following
prohibited equipment: firearms, ammunition, grenade launchers, bayonets, or weaponized
aircraft, vessels, or vehicles of any kind with weapons installed. Expenditures for items
unrelated to grant allowable activities, such as general-use software, general-use computers, and
related equipment (other than for allowable M&A activities or for other associated preparedness
or response functions), general-use vehicles, licensing fees, weapons systems, and ammunition
are also prohibited;
• Personnel costs (except as detailed above or otherwise allowed by statute);
• Activities unrelated to the completion and implementation of the IPR program;
• Other items not in accordance with the AEL or not previously listed as allowable costs;
• Costs related to any matching or cost share requirement for any other federal award;
• Costs related to lobbying or intervention in federal regulatory proceedings;
• Costs related to suing the Federal Government or any other government entity;
• Pre-award costs, unless approved in writing by FEMA and included in the grant award; and
• Costs that are not consistent with the Cost Principles located in FAR 31.2, as applicable.
Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses, and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
Grant funds are intended to support the National Preparedness Goal and to fund projects that build and
sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and
recover from those threats that pose the greatest risk to the security of the Nation. In order to provide
recipients with the ability to meet this objective, the policy set forth originally in IB 379: Guidance to
IPR Appendix | May 2022 Page F-13
State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows
for the expansion of eligible maintenance and sustainment costs that must be (1) in direct support of
existing capabilities, (2) an otherwise allowable expenditure under the applicable grant program, and (3)
tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible
costs may also be in support of equipment, training, and critical resources that have previously been
purchased with either federal grant or any other source of funding other than FEMA preparedness grant
program dollars.
Encouraged Use of Certain Products Produced in the United States
Pursuant to Executive Order 13858 “Strengthening Buy-American Preferences for Infrastructure
Projects,” FEMA encourages non-federal entities under this grant program to use, to the greatest extent
practicable and consistent with the law, iron and aluminum as well as steel, cement, and other
manufactured products produced in the United States, in projects funded by an award under this grant
program affecting surface transportation, including roadways, bridges, railroads, and transit; aviation;
ports, including navigational channels; water resources projects; energy production, generation, and
storage, including from fossil-fuels, renewable, nuclear, and hydroelectric sources; electricity
transmission; gas, oil, and propane storage and transmission; electric, oil, natural gas, and propane
distribution systems; broadband internet; pipelines; stormwater and sewer infrastructure; drinking water
infrastructure; and cybersecurity. Notwithstanding this encouragement, non-federal entities must take care
that all procurements and contract actions are consistent with law, this Manual and applicable appendices,
the grant program’s NOFO, and the federal procurement standards at 2 C.F.R. §§ 200.317-200.326.
PSGP Program Appendix | May 2022 Page G-1
Program Appendix G:
Port Security Grant Program (PSGP)
As a reminder, while this appendix contains PSGP-specific information and requirements, the main content
of this Manual (non-appendix information) contains important information relevant to all preparedness
grant programs, including the PSGP. Please be sure to read the main content of this Manual in addition to
the program-specific appendices.
PSGP grant recipients and subrecipients may only use PSGP grant funds for the purposes set forth in the
Notice of Funding Opportunity (NOFO), and all investments must be consistent with the statutory authority
for the award. These grant funds may not be used for matching funds for other federal awards, lobbying, or
intervention in federal regulatory or adjudicatory proceedings. In addition, federal funds may not be used to
sue the Federal Government or any other government entity.
PSGP Funding Guidelines
Costs charged to a PSGP award must be consistent with the Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, located at 2 C.F.R. Part 200. For more information
on 2 C.F.R. Part 200, please visit Information Bulletin (IB) 400 regarding FEMA’s implementation of these
provisions prior to the recent 2020 revisions. For information on the recent revisions to these regulations,
see 2 CFR Grants Management Policy Updates | FEMA.gov.
PSGP Priorities
See the annual PSGP NOFO.
Limitations on Funding
As part of the PSGP application process, applicants must complete the approved Investment Justification
(IJ) template and included detailed budget sheets (incorporated into the IJ) provided addressing each
initiative being proposed for funding. A single IJ should be submitted with each application. Each IJ should
include all proposed projects in separate tabs within the IJ. A corresponding detailed budget tab is included
within the IJ and must be completed for each project. Each project should represent the complete scope of
work and materials required to achieve a single overall capability. For example, a project could be to
procure a boat specifically designed and equipped as chemical, biological, radiological, nuclear and
explosives (CBRNE) detection, prevention, response, and/or recovery platform. The IJ for this example
project should include the CBRNE equipment in the same IJ as the vessel. The corresponding detailed
budget should include a description of the equipment (i.e., 24’ Response Vessel) and computation (i.e., 1 x
$375,000, total $375,000; Vessel mounted Rad/Nuke detection device, 1 x $25,000, total $25,000).
Additionally, the total computation for the Total Project Cost, Federal Share, and non-Federal Share must
be included in the detailed budget (i.e., Total $400,000; Federal Share $300,000; non-Federal Share
$100,000). This demonstrates that the applicant and FEMA understand the level of Federal funding
requested, as well as a commitment to the Cost Share required by the applicant to complete the project. (see
“Cost-Share or Match” in the PSGP NOFO).
In accordance with 46 U.S.C. § 70107(b)(2), PSGP funding for projects for the cost of acquisition,
operation, and maintenance of security equipment or facilities to be used for security monitoring and
PSGP Program Appendix | May 2022 Page G-2
recording, security gates and fencing, marine barriers for designated security zones, security-related lighting
systems, remote surveillance, concealed video systems, security vessels, and other security-related
infrastructure or equipment that contributes to the overall security of passengers, cargo, or crewmembers
cannot exceed $1 million federal share per project.
The $1 million per project limitation applies only to those projects funded under 46 U.S.C. § 70107(b)(2)
and does not apply to projects funded under other provisions of Section 70107.
Allowable Direct Costs
Specific investments made in support of the funding priorities discussed in the annual PSGP NOFO
generally fall into one of the following six allowable expense categories:
• Planning;
• Operational Activities;
• Equipment and Capital Projects;
• Training and Awareness Campaigns;
• Exercises; and
• Management and Administration.
The following provides guidance on allowable costs within each of these areas.
Planning
Planning activities address the Soft Targets/Crowded Places; Cybersecurity; and Planning Priorities.
PSGP funds may be used for the following types of planning activities:
• Development or updating of port wide risk mitigation plan (PRMP), including the conduct of port
security vulnerability assessments as necessary to support plan update/development;
• Development and enhancement of security plans and protocols within the Area Maritime Security
Plan (AMSP), PRMP, and the Business Continuity and Resumption of Trade Plans (BCRTP) in
support of maritime security and risk mitigation planning;
• Materials required to conduct planning activities noted in this section;
• Travel and per diem related to the professional planning activities noted in this section;
• Coordination and information sharing with fusion centers;
• Planning activities related to alert and warning capabilities;
• Conducting risk and resilience assessments on increasingly connected cyber and physical systems,
on which security depends, using the Infrastructure Resilience Planning Framework and related
CISA resources;
• Other port wide maritime security project planning activities, which emphasize the ability to adapt
to changing conditions and be prepared to withstand, and recover from, disruptions due to
emergencies with prior approval from FEMA; and
• Backfill, overtime, hiring of part-time temporary personnel, and contractors or consultants to assist
with planning activities. Copies of PSGP-funded plans must be made available to FEMA and the U.
S. Coast Guard (USCG) upon request.
Operational Activities
Operational Activities address the Soft Targets/Crowded Places Priority.
PSGP Program Appendix | May 2022 Page G-3
Explosive Detection Canine Teams (EDCTs)
Use of canines (K-9) for explosive detection is one of the most effective solutions for the detection of
vehicle-borne IEDs. When combined with the existing capability of a port or ferry security/police force, the
added value provided through the addition of a canine team is significant. EDCTs are a proven, reliable
resource to detect explosives and are a key component in a balanced counter-sabotage program.
Eligibility for funding of EDCTs is restricted to:
• U.S. Ferry Systems regulated under 33 C.F.R. Parts 101, 103, 104, and the passenger terminals
these specific ferries service under 33 C.F.R. Part 105;
• Maritime Transportation Security Act (MTSA) regulated facilities; and
• Port authorities, port police, and local law enforcement agencies that provide direct layered security
for these U. S. Ferry Systems and MTSA-regulated facilities, and are defined in an AMSP, Facility
Security Plan (FSP), or Vessel Security Plan (VSP).
Applicants may apply for up to $450,000 ($150,000/year for three years) per award to support this
endeavor. At the end of the grant period (36 months), recipients will still be responsible for continuing the
heightened level of capability provided by the EDCT. A sustainment plan must be submitted with the
applicant’s IJ to address the 12-month period beyond the period of performance of the award.
Eligible EDCT Costs
Funds for these EDCTs may not be used to fund drug detection and apprehension technique training. Only
explosives detection training for EDCTs will be funded. The PSGP EDCT funds may only be used for new
or expanded capabilities/programs and cannot be used to pay for existing K-9 teams, personnel, or K-9
training costs already supported by the port area. Repair and replacement of existing EDCT equipment is
allowed. Eligible costs include:
• Contracted K-9 and handler providing services in accordance with PSGP guidance;
• Salary and fringe benefits of new full- or part-time K-9 handler positions;
• Training and certifications (travel costs associated with training for new or expanded full or part
time agency handlers, and canines are allowable);
• K-9 and handler equipment costs;
• Purchase and train a new K-9 and handler for CBRNE detection; and
• K-9 maintenance costs including but not limited to veterinary, housing, and feeding costs.
Ineligible EDCT costs include, but are not limited to:
• Hiring costs, including costs associated with initial police academy training of new officers;
• Meals and incidentals associated with travel for initial certification;
• Vehicles modified to be used solely to transport canines; and
• Repair or replacement of unallowable equipment.
EDCT Certification
Each EDCT, composed of one dog and one handler, must be certified by an appropriate, qualified
organization. K-9 and handler should receive an initial basic training course and weekly maintenance
training sessions thereafter to maintain the certification. The basic training averages ten weeks for the
canine team (K-9 and handler together) with weekly training and daily exercising. Comparable training and
certification standards, such as those promulgated by the Transportation Security Administration (TSA)
Explosive detection canine program, the National Police Canine Association (NPCA), the U.S. Police
Canine Association (USPCA), or the International Explosive Detection Dog Association (IEDDA) may be
PSGP Program Appendix | May 2022 Page G-4
used to meet this requirement. Certifications and training records will be kept on file with the recipient and
made available to FEMA upon request.
EDCT Submission Requirements
Successful applicants will be required to submit an amendment to their approved VSP or FSP per 33 C.F.R.
Parts 104 and/or 105 detailing the inclusion of a K-9 explosive detection program into their security
measures. The recipient will ensure that a written plan or standard operating procedures (SOPs) exist that
describe EDCT deployment policy to include visible and unpredictable deterrent efforts and on-call EDCTs
rapid response times as dictated by the agency’s FSP or VSP. The plan or SOPs must be made available to
FEMA and USCG upon request.
The recipient will comply with requirements for the proper storage, handling, and transportation of all
explosive training aids in accordance with the Bureau of Alcohol, Tobacco, Firearms and Explosives’
Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law and Regulations.
Additional EDCT Resources Available for K-9 Costs
The PSGP, while providing the ability to defray some start-up costs, does not cover any recurring costs
associated with EDCT programs. FEMA strongly encourages applicants to investigate their eligibility under
other programs, and potential exclusions, when developing their K-9 programs.
Organization Costs
Allowable organization-related costs are limited to those activities associated with new and ongoing
maritime security operations essential to the national priorities. All such activities must be focused
exclusively on maritime security and coordinated with the local Captain of the Port (COTP). PSGP funding
used for organizational costs will only fund immediate needs for personnel that will be directly engaged in
maritime security activities. Allowable organization personnel costs include:
• Backfill, Overtime, Hiring of Full or Part-Time Personnel or Contractors/Consultants. Full or
part-time staff or contractors/consultants may be hired to support training-related and/or maritime-
security-related activities conducted under this grant only to the extent that such expenses are for
the allowable activities within the scope of the grant. Hiring of contractors/consultants must follow
the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. Salary and fringe
benefit payments must be in accordance with the policies of the state or unit(s) of local government
and have the approval of the state or awarding agency. Dual compensation is not allowable. That is,
an employee of a unit of government may not receive compensation from their unit or agency of
government AND from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even
though such work may benefit both activities. Limitations may apply for grant related activities.
See specific guidance provided within this Manual for additional details on allowable organization
costs (i.e., Training – Personnel costs are limited to backfill and overtime).
• Hiring new, full-time personnel to:
o Operate maritime security patrol vessels (first response agencies only);
o Staff a new or expanded interagency maritime security operation center;
o Support maritime security/counterterrorism efforts in the local Joint Terrorism Task Force
(JTTF) and/or fusion center; and
o Support credentialing access to a MTSA facility.
• Backfill and Overtime costs for existing personnel to:
o Operate patrol vessels in support of pre-planned, mission critical activities, as identified by
the local COTP (not including routine patrol); and
o Attend approved maritime security training courses.
PSGP Program Appendix | May 2022 Page G-5
• Personnel or contracted costs to:
o Install, repair, and replace port security equipment acquired with FEMA preparedness grant
funds. Note this does not include routine maintenance, such as oil changes and
daily/weekly systems tests; and
o Management and administration (M&A) of projects funded under this program.
• Contracted costs to:
o Provide approved training courses; and
o Provide warranty, maintenance, and service agreements for equipment purchased under this
grant.
Organization costs will only be funded to address port (or facility) security needs as outlined in the NOFO
and this appendix. PSGP funding for new permanent or part-time personnel will not exceed the 36-month
period of performance. Applicants must provide reasonable assurance that personnel costs can be sustained
beyond the 36-month award period. A sustainment plan must be submitted with the applicant’s IJ to
address the 12-month period beyond the period of performance of the award.
Equipment and Capital Projects
Equipment and Capital Projects address the Soft Targets/Crowded Places; Cybersecurity; and
Equipment/Capital Projects Priorities.
Equipment Acquisition
PSGP funds must comply with IB 426. PSGP funds may be used for the following categories of equipment.
A comprehensive listing of allowable equipment categories and types is found in the Authorized Equipment
List (AEL). Requests for vehicles of any type are subject to secondary review and approval by the National
Review Panel. These costs include:
• Personal Protective Equipment (PPE) for maritime security providers, such as ballistic protective
body armor (not including uniforms);
• CBRNE response and remediation equipment for maritime security providers;
• CBRNE decontamination equipment for direct maritime security providers and MTSA-regulated
industry;
• CBRNE detection-equipped patrol vehicles (not including armored personnel carriers or tow
trucks), provided they will be used exclusively for port/facility CBRNE detection security
operations. A CBRNE detection equipped patrol vehicle must include specifically identified,
permanently mounted detection equipment;
• Trailers (not vehicles) designed to carry maritime security equipment essential to maritime security,
mitigation, and response (such as boat trailers, dive trailers, or mobile command trailers);
• Mobile Command Centers only when validated by the COTP as essential to address a
specifically required capability outlined in the approved AMSP. This does not include prime
movers (tow-trucks), personnel carriers, or equipment transport vehicles;
• CBRNE detection-equipped and patrol watercraft vessel/small boat used to directly support
maritime security for a facility or within a Port Area on a routine basis (CBRNE detection
equipment requested with the watercraft/small boat in the IJ must be listed and also detailed in the
budget). However, a vessel is not required to be CBRNE equipped;
• Marine firefighting vessels, provided they are outfitted with CBRNE detection equipment and are
designed and equipped to meet NFPA 1925: Standard on Marine Fire-Fighting Vessels;
• Firefighting foam and Purple-K Powder (PKP) may be purchased by public fire departments that
have jurisdictions in a port area and would respond to an incident at an MTSA regulated facility;
PSGP Program Appendix | May 2022 Page G-6
MTSA facilities may also receive funding for this purpose. Funding will be limited to a one-time
purchase based on a worst-case incident at the facility or facilities;
• Information-sharing technology; components or equipment designed to share maritime security risk
information and maritime all-hazards risk information with other agencies (equipment must be
compatible with generally used equipment);
• Maritime security risk mitigation interoperable communications equipment, including alert and
warning capabilities;
• Terrorism incident prevention and response equipment for maritime security risk mitigation;
• Physical security enhancements, to include TWIC projects (e.g., card readers, fences, blast resistant
glass, turnstiles, hardened doors, and vehicle gates) at maritime facilities;
• Portable fencing, closed-circuit televisions (CCTVs), passenger vans, minibuses, etc. to support
secure passage of vessel crewmembers through a MTSA regulated facility;
• Equipment that enhances continuity capabilities, such as interoperable communications, intrusion
prevention/detection, physical security enhancements, software and other equipment needed to
support essential functions during a disruption to normal operations;
• Generators with appropriate capability (size) to provide back-up power to systems and equipment
that support Maritime Domain Awareness (not including routine operational capabilities):
o Access control equipment and systems;
o Detection and security surveillance equipment; and
o Enhancement of Command-and-Control facilities.
• Equipment for new personnel, such as personal protective equipment, is an allowable expense.
Weapons and equipment associated with weapons maintenance/security (e.g., firearms,
ammunition, and gun lockers) are not allowable.
Recipients may purchase equipment not listed on the AEL, but only if they first seek and obtain prior
approval from FEMA. In addition, recipients that are using PSGP funds to support emergency
communications equipment activities must comply with the SAFECOM Guidance on Emergency
Communications Grants, including provisions on technical standards that ensure and enhance interoperable
communications. This SAFECOM Guidance can be found at https://www.cisa.gov/safecom/funding.
Requirements for Small Unmanned Aircraft Systems
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and also include a description of the policies and procedures in place to safeguard individuals’
privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or otherwise use the
sUAS equipment. SUAS policies are not required at the time of application but must be received and approved
by FEMA prior to obligating PSGP funds. All grant-funded procurements must be executed in a manner
compliant with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. For recipients that use
PSGP funds for sUAS, FEMA advises that there is a general privacy concern related to the use of this
equipment if the data the devices collect is transmitted to servers not under the control of the operator. It has
been reported that some manufacturers of sUAS encrypt data and send that data to servers outside the
United States. The U.S. Department of Homeland Security’s Privacy Office suggests the recipient fully
explore data transmission and storage issues with vendors to reduce the possibility of data breaches.
Additionally, the Joint Explanatory Statement (JES) accompanying the FY 2022 DHS Appropriations further
requires recipients to certify they have reviewed the Industry Alert on Chinese Manufactured Unmanned
Aircraft Systems, and completed a risk assessment that considers the proposed use of foreign-made sUAS to
ascertain potential risks (e.g., privacy, data breaches, cybersecurity, etc.) related to foreign-made versus
domestic sUAS.
PSGP Program Appendix | May 2022 Page G-7
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA was alerted of an advisory guidance document issued by DHS, the Department of
Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.
The purpose of the advisory guidance document is to help non-federal public and private entities better
understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate
threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
representations of the systems’ legality or functionality. Please also see the DHS press release on this topic
for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-technology-
detect-and-mitigate-unmanned-aircraft.
Sonar Devices
The four types of allowable sonar devices are: imaging sonar, scanning sonar, side scan sonar, and three-
dimensional sonar. These types of sonar devices are intended to support the detection of underwater
improvised explosive devices and enhance maritime domain awareness. The eligible types of sonar, and
short descriptions of their capabilities, are provided below:
1) Imaging Sonar: A high-frequency sonar that produces “video-like” imagery using a narrow field
of view. The sonar system can be pole-mounted over the side of a craft or hand-carried by a diver.
2) Scanning Sonar: Consists of smaller sonar systems that can be mounted on tripods and lowered to
the bottom of the waterway. Scanning sonar produces a panoramic view of the surrounding area
and can cover up to 360 degrees.
3) Side Scan Sonar: Placed inside a shell and towed behind a vessel. Side scan sonar produces strip-
like images from both sides of the device.
4) Three-Dimensional Sonar: Produces 3-dimensional imagery of objects using an array receiver.
Maritime Domain Awareness
Maritime domain is defined as “all areas and things of, on, under, relating to, adjacent to, or bordering on a
sea, ocean, or other navigable waterway, including all maritime-related activities, infrastructure, people,
cargo, and vessels and other conveyances.” Homeland Security Presidential Directive-13 (NSPD-41/HSPD-
13) (Maritime Security Policy, December 21, 2004). According to the National Plan to Achieve Maritime
Domain Awareness for the National Strategy for Maritime Security (Oct. 2005), “Maritime Domain
Awareness (MDA) is the effective understanding of anything associated with the global maritime domain
that could impact the security, safety, economy, or environment of the United States. MDA is a key
component of an active, layered maritime defense in depth. It will be achieved by improving our ability to
collect, fuse, analyze, display, and disseminate actionable information and intelligence to operational
commanders.” Id. at ii. Applicants are encouraged to familiarize themselves with this National Strategy.
PSGP Program Appendix | May 2022 Page G-8
Improvised Explosive Device (IED) and CBRNE Prevention, Protection, Response, Recovery
Capabilities
Port areas should continue to enhance their capabilities to prevent, detect, respond to, and recover from
terrorist attacks employing IEDs, CBRNE devices, and other non-conventional weapons. Please refer to
DHS Small Vessel Security Strategy (Apr. 2008).
Physical Security
Physical security is security measures that are designed to deny unauthorized access to facilities, equipment,
and resources and to protect personnel and property from damage or harm (such as espionage, theft, or
terrorist attacks). Physical security involves the use of multiple layers of interdependent systems and
techniques. Physical security has been a focus of PSGP since the program’s inception in 2002. Primarily,
physical security is intended to harden MTSA-regulated facilities against attacks. Law enforcement may
contribute to physical security through patrols; however, patrol vessels generally enhance multiple core
capabilities with a focus on CBRNE detection, deterrence, and response. Funding through PSGP for
physical security projects should be only directed toward those projects that address identified MTSA
required activities and identified in the entity FSP and/or the port area AMSP. Some examples of funded
projects include TWIC-related equipment, fencing, lighting, gates, and CCTV. Physical security projects
typically require EHP review prior to obligating PSGP funds.
Cybersecurity Projects
PSGP funds may be used for projects that enhance the cybersecurity of:
• Access controls;
• Sensors;
• Security cameras;
• Badge/ID readers;
• Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems;
• Process monitors and controls (such as firewalls, network segmentation, predictive security cloud,
etc.); and
• Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable).
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in
implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the
“Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework
gathers existing international standards and practices to help organizations understand, communicate, and
manage their cyber risks. For organizations that do not know where to start with developing a cybersecurity
program, the Framework provides initial guidance. For organizations with more advanced practices, the
Framework offers a way to improve their programs, such as better communication with their leadership and
suppliers about management of cyber risks.
The Cybersecurity and Infrastructure Security Agency’s (CISA) Critical Infrastructure Cyber Community
C³ Voluntary Program also provides resources to critical infrastructure owners and operators to assist in
adoption of the Framework and managing cyber risks. Additional information on the Critical Infrastructure
Cyber Community C³ Voluntary Program can be found at http://www.cisa.gov/ccubedvp. DHS’s Enhanced
Cybersecurity Services (ECS) program is an example of a resource that assists in protecting U.S.-based
public and private entities and combines key elements of capabilities under the “Detect” and “Protect”
functions to deliver an impactful solution relative to the outcomes of the Cybersecurity Framework.
Specifically, ECS offers intrusion prevention and analysis services that help U.S.-based companies and
SLTT governments defend their computer systems against unauthorized access, exploitation, and data
exfiltration. ECS works by sourcing timely, actionable cyber threat indicators from sensitive and classified
Government Furnished Information (GFI). DHS then shares those indicators with accredited Commercial
PSGP Program Appendix | May 2022 Page G-9
Service Providers (CSPs). Those CSPs in turn use the indicators to block certain types of malicious traffic
from entering a company’s networks. Groups interested in subscribing to ECS must contract directly with a
CSP in order to receive services. Please visit http://www.cisa.gov/enhanced-cybersecurity-services-ecs for a
current list of ECS CSP points of contact.
“Hub and spoke” cybersecurity projects are allowable under PSGP for cybersecurity projects that span
multiple port area facilities. Hub and spoke cybersecurity projects may affect a parent organization’s
multiple eligible entities, and maritime security partners, in multiple port areas to provide a port-wide
benefit. Such projects may be submitted within a primary Port Area for the project implementation. For
example, an applicant in the Port of Houston may submit a hub and spoke project within the
Houston/Galveston port area which includes system hardening throughout the organization’s facilities in
Houston, Port Lavaca, and Corpus Christi. Proportionally, costs associated with entities or subcomponents
that are not covered under an AMSP and are not instrumental to enhancing maritime security must not be
included in the detailed budget worksheet or investment justification and thereby prorating the cost of the
project only to those facilities that are covered by the AMSP. Following the example noted above, the
applicant may not include costs associated with cybersecurity of their non-maritime facilities, such as a
non-MTSA regulated facility located in San Antonio. Hub and spoke projects are limited only to the
enhancement of maritime security as outlined in this section and may not include non-maritime systems or
facilities. Please clearly identify hub and spoke projects as such within your IJ and consult your COTP to
verify project applicability to enhancing maritime security.
Cybersecurity projects should address risks to the marine transportation system and/or Transportation
Security Incidents (TSIs) outlined in the applicable AMSP, or priorities prescribed under applicable FSP
or VSP, as mandated under the MTSA or the PRMPs. At the port level, examples of cybersecurity
projects include but are not limited to projects that enhance the cybersecurity of access control, sensors,
security cameras, badge/ID readers, ICS/SCADA systems, process monitors and controls (such as those
that monitor flow rates, valve positions, tank levels, etc.), security/safety of the ship-to-port-to-facility-to-
intermodal interface, and systems that control vital cargo machinery at the ship/shore interface (such as
cranes, manifolds, loading arms, etc.), and passenger/vehicle/cargo security screening equipment.
Vulnerability assessments are generally not funded under PSGP. However, considering the evolving
malicious cyber activity, the relative novelty of cybersecurity as a priority within the program, and the need
to adopt best practices included in the voluntary Cybersecurity Framework, vulnerability assessments may
be funded as contracted costs. Port-wide assessments are eligible and must demonstrate that the assessment
includes port area partners and are necessary to be completed as a single project to ensure a comprehensive
evaluation of port area cyber security vulnerabilities. Personnel costs (other than M&A) are not an
allowable expense for conducting these assessments.
CISA offers free resources to assist with initial assessments, please see https://www.cisa.gov/cyber-
resource-hub for additional information. Applicants are encouraged to utilize free resources prior to
requesting funds under this program.
Copies of completed cybersecurity assessments funded under PSGP that impact the maritime
transportation system, lead to a “transportation security incident” (as that term is defined under 46
U.S.C. § 70101(6)), or are otherwise related to systems, personnel, and procedures addressed by the
facility and vessel plan shall be made available to FEMA and/or the local COTP upon request. The
results of these cybersecurity assessments may be designated as Sensitive Security Information (SSI) and
may be used to inform national maritime cybersecurity assessments.
Where a vulnerability assessment has been completed either through contracts or qualified personnel to
identify existing gaps and required mitigation efforts, mitigating projects may be funded that include
PSGP Program Appendix | May 2022 Page G-10
purchase of equipment, software, and infrastructure designed to harden cybersecurity. Specific questions on
conducting vulnerability assessments should be referred to the respective FEMA Preparedness Officer.
Capital (Construction) Projects Guidance
Recipients must obtain written approval from FEMA prior to the use of any PSGP funds for construction or
renovation projects. Additionally, PSGP funding may not be used to construct buildings or other physical
facilities that are not constructed under terms and conditions consistent with the requirements of section
611(j)(9) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. § 5196(j)(9))
(the Stafford Act),3 which requires compliance with the Davis-Bacon Act (codified as amended at 40 U.S.C.
§§ 3141 et seq.) for PSGP funded projects. Grant recipients must ensure that their contractors or
subcontractors for construction projects pay workers no less than the prevailing wages for laborers and
mechanics employed on projects of a character similar to the contract work in the civil subdivision of the
state in which the work is to be performed. Additional information regarding compliance with the Davis-
Bacon Act, including Department of Labor wage determinations, is available at
http://www.dol.gov/whd/govcontracts/dbra.htm.
The following types of construction and renovation projects are allowable under PSGP, provided they
address a specific vulnerability or need identified in AMSP or otherwise support the
maintenance/sustainment of capabilities and equipment acquired through PSGP funding:
• Maritime Command and Control Centers;
• Interagency Operations Centers (IOCs) for maritime security;
• Port Security Emergency Communications Centers;
• Buildings to house generators that support maritime security risk mitigation;
• Maritime security risk mitigation facilities (e.g., dock house, ramps, and docks for existing port
security assets);
• Hardened security fences/barriers at access points;
• Any other building or physical facility that enhances access control to the port/MTSA facility area;
and
• PSGP funding may be used to purchase and/or upgrade a barge to support a staging area for
maritime/port security patrols or maritime security risk mitigation responses. (Certain areas
throughout the Nation may require a barge that can be permanently anchored or moored in certain
areas to support maritime security risk mitigation activities.).
To be considered eligible for funding, the construction of fusion centers, operations centers, or
communications centers must offer a port wide benefit and support information sharing and operational
coordination among regional interagency and other port security partners. Applicants are reminded that the
period of performance is 36 months. Eligible costs for construction or renovation projects may not exceed
$1 million (federal share) per project, which may not exceed 10% of the total amount of the award, as stated
in 46 U.S.C. § 70107(b)(2)(A) and (B) (Section 102 of the Maritime Transportation Security Act of 2002,
Pub. L. 107-295, as amended). Grant recipients are not permitted to use PSGP funds for construction
projects that are eligible for funding under other federal grant programs. PSGP funds may only be used for
construction activities directly related to maritime security risk mitigation enhancements.
3 While the Maritime Transportation Security Act of 2002, as amended at 46 U.S.C. § 70107(b)(2), requires that such
activities are carried out consistent with Section 611(j)(8) of the Stafford Act, a subsequent amendment to the Stafford
Act by section 3 of Pub. L. No. 109-308 in 2006 redesignated the text of Section 611(j)(8) to 611(j)(9). The cross-
reference in the Maritime Transportation Security Act of 2002 has not been updated.
PSGP Program Appendix | May 2022 Page G-11
All construction or renovation projects require Environmental Planning and Historic Preservation (EHP)
review. The recipient is also encouraged to have completed as many steps as possible for a successful EHP
review in support of their proposal for funding (e.g., coordination with the relevant Historic Preservation
Office to identify potential historic preservation issues and to discuss the potential for project effects;
compliance with all state and local EHP laws and requirements). Projects for which the recipient believes an
Environmental Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01,
Revision 01, EHP Directive and Instruction, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must
also be identified to the FEMA HQ Preparedness Officer within the first six months of the award, regardless
of the length of the period of performance. Completed EHP review materials for construction and
renovation projects must be submitted no later than 12 months before the end of the period of performance.
EHP policy guidance and the EHP Screening Form, can be found online at: https://www.fema.gov/media-
library/assets/documents/90195. EHP review materials should be sent to gpdehpinfo@fema.dhs.gov.
Training and Awareness Campaigns
Training and Awareness Campaigns address the Soft Targets/Crowded Places; Cybersecurity; and
Training and Awareness Campaign Priorities.
Training
Port areas should assess their training and qualification requirements and coordinate training needs and
qualification requirements of incident response personnel. Funding for personnel training is limited to those
courses that are essential to enhance maritime security. A listing of courses that are currently approved for
PSGP funding is included in the table below.
Some training activities require EHP Review, including exercises, drills or trainings that require any type of
land, water, or vegetation disturbance or building of temporary structures or that are not located at facilities
designed to conduct training and exercises. Additional information on training requirements and EHP review
can be found online at: https://www.fema.gov/media-library/assets/documents/90195.
Funding for training courses not listed in Table 3 may be permitted on a case-by-case basis depending on
the specific maritime security risk mitigation training needs of the eligible PSGP applicant. In such cases,
an applicant will be required to explain in the IJ why none of the approved courses referenced in Table 3
satisfy the identified training need and must submit detailed course information for review and
consideration by the local COTP field review team and the Nation Review Panel.
Further, in accordance with 46 U.S.C. § 70107(c)(2)(C), no cost share is required to train public safety
personnel in the enforcement of security zones under section 46 U.S.C. § 70132 or assisting the
enforcement of such security zones. Per 46 U.S.C. § 70132(d), the term “public safety personnel” includes
any federal, state (or political subdivision thereof), territorial, or tribal law enforcement officer, firefighter,
or emergency response provider
Training denoted with an asterisk (*) in the table below is exempt from cost share only to train public safety
personnel who enforce security zones. Additional training of public safety personnel may be exempt if
specifically identified by the COTP as exempt and necessary for enforcement or the assistance of
enforcement of security zones as specified by 46 U.S.C. § 70132. Requests that fail to include a cost
share for training that is not exempt from cost share requirements as outlined in 46 U.S.C. § 70132
will not be considered for funding. Training for public safety personnel who do not provide enforcement
of security zones are not exempt from cost share. Training rosters and certificates must be provided to
FEMA upon request. Please consult your COTP prior to requesting cost share exempt training for
enforcement of security zones. Refer to Section C.4 of the NOFO for more specific cost share information
for that specific year’s requirements.
PSGP Program Appendix | May 2022 Page G-12
Seminars and workshops are not considered “Training”, however applicants wishing to host seminars or
workshops with PSGP funding may be eligible for funding following the criteria set forth in the “Exercise”
section of this guidance.
Table 3: Approved PSGP Training Courses
National Training and Education Division
Course Number Course Name
AWR-144 Port and Vessel Security for Public Safety and Maritime Personnel
AWR-213 Critical Infrastructure Security and Resilience Awareness
AWR-366-W Developing a Cyber Security Annex for Incident Response
MGT-335 Event Security Planning for Public Professionals
MGT-335-W Event Security Planning for Public Professionals, Web Based
MGT-400 Master of Arts Degree in Homeland Security
MGT-425 Homeland Security Executive Leaders Program (ELP)
MGT-452 Physical and Cybersecurity for Critical Infrastructure
MGT-456 Integration of Cybersecurity Personnel into the Emergency Management
Operations Center for Cyber Incidents
PER-330 The Surface Transportation Emergency Preparedness and Security for Mass
Transit and Passenger Rail (STEPS-PT)
PER-331 Surface Transportation Emergency Preparedness and Security for Senior
Officials or Administrators (STEPS Sr)
Federal-Sponsored
Course Number Course Name
DHS-006-PREV Seaport Security Anti-Terrorism Training Program (SSATP)
DHS-011-PREV Maritime PRND Operations Course
DHS-016-PREV Protective Measures Training for Security Officers, Mid-Level
Safety/Security Supervisors, and Property Managers
*DHS-011-PROT NASBLA BOAT Tactical Operators Course
*DHS-009-PROT Boat Operator's Anti-Terrorism Training
DHS-126-RESP NASBLA BOAT Crew Member Course
*DHS-128-RESP NASBLA - Pursuit and Stop Course
State-Sponsored
Course Number Course Name
CA-006-PREV Maritime Company, Vessel, and Facility Security Officer
CA-007-PREV Basic Maritime Security Awareness
CA-008-PREV Basic First Responder Operational Maritime Security (FROMS)
CA-015-RESP Maritime Facility Security Officer
CA-020-RESP WMD & Terrorism Awareness for Security Professionals
ME-001-PROT Maritime Security Awareness for Military, First Responder and Law
Enforcement Personnel
ME-002-PROT Command Strategies and Tactics for Marine Emergencies
*ME-003-PROT Tactical Boat Operations for Maritime Security and LE Personnel
ME-002-RESP Emergency Medical Operations in the Maritime Domain
NJ-003-PREV Government Agency Maritime Security Awareness Program (GAMSAP)
NJ-015-PREV Security Awareness & Vigilance for Everyone
NY-001-PREV Maritime Infrastructure Protection
NY-001-PROT Safe Boat Operators
*NY-002-PREV Tactical Escorts and Security Zones
NY-002-PROT Pattern Line Search/Recovery Course
NY-004-RESP Vehicle Borne Improvised Explosive Device Security Checkpoint
PSGP Program Appendix | May 2022 Page G-13
Federal Law Enforcement Training Center (FLETC)
Course Number Course Name
*MTOTP Marine Law Enforcement Training Program
IBOT Inland Boat Operator’s Training
ENTP Electronic Navigation Training Program
*BOAT Boat Operator’s Anti-Terrorism Training Program
Exercises
Exercise activities address the Soft Targets/Crowded Places; Cybersecurity; and Exercises Priorities.
Exercises funded under the PSGP typically include Seminars, Workshops, Tabletop, Functional, Drills, and
Full-Scale exercises. PSGP-funded exercises must have a maritime security focus and include applicable
documentation, after action reports, and improvement plans. See below for additional information.
Maritime entity training needs and qualification requirements of incident response personnel should be
regularly tested through emergency exercises and drills. Exercises must test operational protocols that
would be implemented in the event of a terrorist attack in the maritime environment in accordance with the
Area Maritime Security Training Exercise Program (AMSTEP) or the TSA Intermodal Security Training
Exercise Program (I-STEP) guidelines. AMSTEP or I-STEP exercises will follow the latest change in
requirements contained in the Navigation and Inspection Circular (NVIC) 09-02. Exercises must be
designed, developed and conducted consistent with the Homeland Security Exercise and Evaluation
Program (HSEEP). Funding used for exercises will only be permitted for those exercises that are in direct
support of a MTSA-regulated facility or a port area’s MTSA-required exercises (see 33 C.F.R. § 105.220
for a facility and 33 C.F.R. § 103.515 for the AMSP). These exercises must be coordinated with the COTP
and AMSC and be consistent with HSEEP. More information on HSEEP may be found at
https://www.fema.gov/emergency-managers/national-preparedness/exercises/hseep.
Some exercise activities require EHP Review, including exercises, drills or trainings that require any type of
land, water, or vegetation disturbance or building of temporary structures or that are not located at facilities
designed to conduct training and exercises. Additional information on training requirements and EHP review
can be found online at https://www.fema.gov/media-library/assets/documents/90195.
Recipients are required to submit an After-Action Report/Improvement Plan (AAR/IP) for each PSGP-
funded exercise to hseep@fema.dhs.gov, and the appropriate local COTP no later than 90 days after
completion of the exercise conducted within the PSGP period of performance (POP). Recipients are
reminded of the importance of implementing corrective actions iteratively throughout the progressive
exercise cycle. Recipients are required to use the HSEEP AAR/IP template located at
https://preptoolkit.fema.gov/web/hseep-resources/improvement-planning.
Recipients of PSGP funding for exercises should verify in progress reports the completion of the
exercise(s), after-action report(s), improvement plan(s), and notifications made to hseep@fema.dhs.gov and
the COTP.
PSGP funds may be used for the following exercise activities:
Funds Used to Design, Develop, Conduct, and Evaluate an Exercise. This includes costs related to
planning, meeting space, and other meeting costs, facilitation costs, materials and supplies, travel, and
documentation. Exercises afford organizations the opportunity to validate plans and procedures, evaluate
capabilities, and assess progress toward meeting capability targets in a controlled, low risk setting. Any
shortcoming or gap identified, including those for children and individuals with disabilities or access and
PSGP Program Appendix | May 2022 Page G-14
functional needs, should be identified in an effective corrective action program that includes development
of improvement plans that are dynamic documents, with corrective actions continually monitored and
implemented as part of improving preparedness through the exercise cycle.
Hiring of Full- or Part-Time Staff or Contractors/Consultants. Full- or part-time staff may be hired to
support exercise-related activities. Hiring of contractors/consultants must follow the applicable federal
procurement requirements at 2 C.F.R. §§ 200.317-200.327. Such costs must be included within the funding
allowed for program management personnel expenses, which must not exceed 10% of the total allocation.
Dual compensation is never allowable, meaning, in other words, that an employee of a unit of government
may not receive compensation from his or her unit or agency of government and from an award for a single
period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both entities. Personnel
hiring, overtime, and backfill expenses are permitted under this grant only to the extent that such expenses
are for the allowable activities within the scope of the grant.
Overtime and Backfill Costs. The entire amount of overtime costs, including payments related to
backfilling personnel that are the direct result of time spent on the design, development and conduct of
exercises are allowable expenses. These costs are allowed only to the extent the payment for such services
is in accordance with the policies of the state or unit(s) of local government and has the approval of the state
or the awarding agency, whichever is more restrictive. Dual compensation is never allowable.
Travel. Domestic travel costs are allowable as expenses by employees who are on travel status for official
business related to the planning and conduct of exercise project(s). International travel costs are not
permitted.
Supplies. Supplies are items that are expended or consumed during the course of the planning and conduct
of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective equipment).
Other Items. These costs include the rental of space/locations for exercise planning and executing, rental of
equipment, etc. Recipients are encouraged to use free public space, locations, or facilities, whenever
available, prior to the rental of space, locations, or facilities. These also include costs that may be associated
with inclusive practices and the provision of reasonable accommodations and modifications to provide full
access for children and adults with disabilities.
The National Exercise Program (NEP) serves as the principal exercise mechanism for examining national
preparedness and measuring readiness. Recipients are strongly encouraged to nominate exercises into the
NEP. For additional information on the NEP, please refer to http://www.fema.gov/national-exercise-
program.
Management and Administration (M&A)
M&A costs are allowed under this program. M&A costs are activities directly related to managing and
administering the award. Recipients may use up to 5% of the amount of the award for their M&A. PSGP
funds may be used for the following M&A costs:
• Hiring full-time or part-time staff, including contractors and consultants, to execute the following:
o Management of the awarded fiscal years’ PSGP award;
o Design and implementation of the awarded fiscal years’ PSGP submission meeting
compliance with reporting/data collection requirements, including data calls;
o Information collection and processing necessary to respond to FEMA data calls;
o Travel expenses related to PSGP grant administration; and
PSGP Program Appendix | May 2022 Page G-15
o Acquisition of authorized office equipment, including personal computers or laptops for
PSGP M&A purposes.
Allowable Indirect Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the Grants
Management Specialist for further instructions. Applicants who wish to use a cost allocation plan in lieu of
an indirect cost rate must also reach out to the Grants Management Specialist for further instructions. Post-
award requests to charge indirect costs will be considered on a case-by-case basis and based upon the
submission of an agreement or proposal as discussed above or based upon the de minimis rate or cost
allocation plan, as applicable.
Unallowable Costs
Projects that do not provide a compelling maritime security benefit or have a direct nexus toward maritime
security risk mitigation are not permitted. For example, projects that are primarily for economic or safety
benefit (as opposed to having a direct maritime security risk mitigation benefit) are ineligible for PSGP
funding. In addition, projects that provide a broad homeland security benefit (e.g., a communication system
or fusion center for an entire city, county, state, etc.) as opposed to providing primary benefit to the port are
ineligible for PSGP funding since these projects should be eligible for funding through other preparedness
grant programs. The following projects and costs are considered ineligible for award consideration:
• Grant funds must comply with IB 426 and may not be used for the purchase of the following
equipment: firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft, vessels, or
vehicles of any kind with weapons installed;
• Projects in which federal agencies are the primary beneficiary or that enhance federal property,
including sub-components of a federal agency;
• Projects that study technology development for security of national or international cargo supply
chains (e.g., e-seals, smart containers, container tracking or container intrusion detection devices);
• Proof-of-concept projects;
• Development of training;
• Projects that duplicate capabilities being provided by the Federal Government (e.g., vessel traffic
systems);
• Business operating expenses (certain security-related operational and maintenance costs are
allowable—see “Maintenance and Sustainment” and “Operational Costs” for further guidance);
• Transportation Worker Identification Credential (TWIC) card fees;
• Reimbursement of pre-award security expenses;
• Outfitting facilities, vessels, or other structures with equipment or items providing convenience
rather than a direct security benefit. Examples of such equipment or items include but are not
limited to office furniture, CD players, DVD players, AM/FM radios, TVs, stereos, entertainment
satellite systems, entertainment cable systems and other such entertainment media, unless sufficient
justification is provided. This includes weapons and associated equipment (i.e., holsters, optical
sights, and scopes), including but not limited to, non-lethal or less-than-lethal weaponry including
firearms, ammunition, and weapons affixed to facilities, vessels, or other structures;
PSGP Program Appendix | May 2022 Page G-16
• Standard issue uniforms (other than maritime security personal protective equipment [PPE]);
• Expenditures for items such as general-use software, general-use computers, and related equipment
(other than for allowable M&A activities, or otherwise associated) preparedness or response
functions), general-use vehicles and licensing fees;
• Land acquisitions and right of way purchases;
• Funding for standard operations vehicles utilized for routine duties, such as patrol cars and fire
trucks;
• Fuel costs (except as permitted for training and exercises);
• Exercise(s) that do not support maritime security preparedness efforts;
• Patrol vehicles and firefighting apparatus, other than those CBRNE detection equipped vehicles for
port area and/or facility patrol or response purposes;
• Specialty vehicles such as trucks for towing boat trailers/equipment and armored personnel carriers;
• Providing protection training to public police agencies or private security services to support
protecting VIPs or dignitaries;
• Aircraft pilot training, including aircraft operations such as aircraft ditch training;
• Post incident investigation training;
• Basic or advanced dive training (except marine unit CBRNE detection/response dive training);
• Training for personnel not primarily assigned to maritime security activities or MTSA required
security personnel (e.g., vessel patrol officers, facility security officers); and
• Reimbursement for the maintenance and wear and tear costs of general use vehicles (e.g.,
construction vehicles) and emergency response apparatus (e.g., fire trucks, ambulances, repair, or
cleaning of PPE, etc.).
Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses, and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase of
the system or equipment is consistent with that which is typically provided for, or available through, these
types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending an
existing maintenance contract on an already-owned piece of equipment system, coverage purchased may
not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
Grant funds are intended to support the National Preparedness Goal and fund projects that build and sustain
the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover
from those threats that pose the greatest risk to the security of the Nation. In order to provide recipients the
ability to meet this objective, the policy set forth in IB 379: Guidance to State Administrative Agencies to
Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for the expansion of eligible
maintenance and sustainment costs that must be in (1) direct support of existing capabilities; (2) must be an
otherwise allowable expenditure under the applicable grant program, and (3) be tied to one of the core
capabilities in the five mission areas outlined in the Goal. Additionally, eligible costs may also be in support
of equipment, training, and critical resources that have previously been purchased with either federal grant
or any other source of funding other than FEMA preparedness grant program dollars.
PSGP Program Appendix | May 2022 Page G-17
Port-Wide Risk Management Plans
Port areas with existing PRMPs are encouraged to maintain their PRMPs and use them to identify projects
that will serve to address remaining maritime security vulnerabilities. These ports are also encouraged to
develop or maintain a BCRTP. For purposes of regional strategic and tactical planning, these plans must
take into consideration all port areas covered by their AMSP, align with the port area’s AMSP, consider the
entire port system strategically as a whole, and identify actions designed to effectively mitigate security
risks associated with the system’s maritime critical infrastructure and key resources.
Additional Port Security Resources
• U.S. Department of Transportation “BUILD” grants for National Infrastructure Investments may
include funding to support roads, bridges, transit, rail, ports, or intermodal transportation, see
https://www.transportation.gov/BUILDgrants
• Cybersecurity assessments may be available via CISA, see https://www.cisa.gov/cyber-resource-
hub
Sample Memorandum of Understanding/Agreement (MOU/MOA)
The sample MOU/MOA below demonstrates all of the elements required in the PSGP NOFO for
acceptance for review as part of a grant application from a state or local agency providing security services
to MTSA-regulated entities.
PSGP Program Appendix | May 2022 Page G-18
PSGP Investment Modifications
The purpose of the grant award is to implement projects pursuant to the authorities at 46 U.S.C. § 70107.
Under extreme circumstances, a recipient may reallocate award funds from one project to another with prior
written approval from FEMA, and in a manner consistent with 2 C.F.R. § 200.308 as long as it does not
change the overall scope or objective of the award. Circumstances include, but are not limited to, an
inability to complete the original project, disaster events perpetuating an immediate need to reprioritize
funds, and changes in regulatory requirements. A recipient must explain the deviation from the original
project, including why it is deviating from or scaling down the original project, and what specific
circumstances that occurred after the time of its award that necessitate the reallocation request, in its
reallocation request. The recipient must also identify how the reallocation request aligns with PSGP
priorities and the recipient’s original application and the award’s scope of work. Due to legal limitations,
reallocation requests that would change the scope of the overall project(s) are not permitted. FEMA will
also coordinate such reallocation requests with the USCG COTP, and these requests must be verified and
supported by the COTP as essential in addressing Port Area priorities. Please also see Section C.4 of this
NOFO regarding cost share requirements, including the implications if the project costs are less than what
was applied for.
Memorandum of [Understanding / Agreement]
Between [provider of layered security] and [recipient of layered security]
Regarding [provider of layered security’s] Use of Port Security Grant Program Funds
1. PARTIES. The parties to this Agreement are the [Provider of Layered Security] and the [Recipient of security
service].
2. AUTHORITY. This Agreement is authorized under the provisions of [applicable Area Maritime Security
Committee (AMSC) authorities and/or other authorities].
3. PURPOSE. The purpose of this Agreement is to set forth terms by which [Provider of security service] shall
expend Port Security Grant Program project funding in providing security service to [Recipient of security
service]. Under requested PSGP grant, the [Provider of security service] must provide layered security to
[Recipient of security service] consistent with the approach described in an approved grant application.
4. RESPONSIBILITIES: The security roles and responsibilities of each party are understood as follows:
(1) [Recipient of security service]
Roles and responsibilities in providing its own security at each MARSEC level
(2) [Provider of security service]
[-An acknowledgement by the facility that the applicant is part of their facility security plan.]
[-The nature of the security that the applicant agrees to supply to the regulated facility (waterside
surveillance, increased screening, etc.).]
[-Roles and responsibilities in providing security to [Recipient of security service] at each MARSEC level.]
5. POINTS OF CONTACT. [Identify the POCs for all applicable organizations under the Agreement; including
addresses and phone numbers (fax number, e-mail, or internet addresses can also be included).]
6. OTHER PROVISIONS. Nothing in this Agreement is intended to conflict with current laws or regulations of
[applicable State] or [applicable local Government]. If a term of this agreement is inconsistent with such
authority, then that term shall be invalid, but the remaining terms and conditions of this agreement shall remain
in full force and effect.
7. EFFECTIVE DATE. The terms of this agreement will become effective on [EFFECTIVE DATE].
8. MODIFICATION. This agreement may be modified upon the mutual written consent of the parties.
9. TERMINATION. The terms of this agreement, as modified with the consent of both parties, will remain in
effect until the grant end dates for an approved grant. Either party upon [NUMBER] day’s written notice to the
other party may terminate this agreement.
APPROVED BY: Organization and Title
EMPG Program Appendix | May 2022 Page H-1
Program Appendix H:
Emergency Management Performance Grant Program
As a reminder, while this appendix contains Emergency Management Performance Grant (EMPG)
Program-specific information and requirements, the main content of this Manual (non-appendix
information) contains important information relevant to all preparedness grant programs, including the
EMPG Program.
FEMA will update and publish the full fiscal year (FY) 2022 version of the Preparedness Grants Manual at
a future date, which will apply to the use of supplemental FY 2022 EMPG Program funds and will apply to
the anticipated eventual full-year FY 2022 EMPG Program funds. Please be sure to read the main content of
this Manual in addition to the program-specific appendices once the full version is published.
EMPG Program Priorities
The national priorities for the FY 2022 EMPG Program are:
• Equity
• Climate Resilience
• Readiness
These priorities correspond directly to goals outlined in the 2022-2026 FEMA Strategic Plan. All EMPG
Program recipients are encouraged to review the strategic plan and consider how FY 2022 EMPG Program
funding can be used to support the Plan’s goals and objectives as they apply to the state/territory’s specific
needs and the needs of the whole community. The national priorities are explained in further detail in the
FY 2022 EMPG Program Notice of Funding Opportunity (NOFO).
Alignment of the EMPG Program to the National Preparedness System
The EMPG Program contributes to the implementation of the National Preparedness System by supporting
the building, sustainment, and delivery of core capabilities. Core capabilities are essential for the execution
of critical tasks for each of the five mission areas outlined in the National Preparedness Goal (the Goal).
The EMPG Program’s allowable costs support efforts to build and sustain core capabilities across the
Prevention, Protection, Mitigation, Response, and Recovery mission areas described in the Goal.
FEMA requires recipients to prioritize grant funding to demonstrate how EMPG Program-funded
investments support closing capability gaps or sustaining capabilities identified in the Threat and Hazard
Identification and Risk Assessment (THIRA)/Stakeholder Preparedness Review (SPR) process and other
relevant information sources, such as: 1) after-action reports (AARs) following exercises or real-world
events; 2) audit and monitoring findings; 3) Hazard Mitigation Plans; and/or 4) other deliberate planning
products. In advance of issuing the FY 2022 EMPG Program awards, FEMA Regional Administrators will
identify individual regional priorities based on their unique knowledge of each region’s preparedness and
emergency management needs and will share those priorities with the states and territories within their
region. The final priorities will be identified and mutually agreed to by the state/territory and Regional
Administrator through a collaborative negotiation process. Ideally, all EMPG Program-funded projects, as
outlined in the approved FY 2022 EMPG Program Work Plan, will support the priorities identified through
this collaborative approach. See EMPG Program Work Plan section for additional guidance.
FEMA continues to place emphasis on capabilities that address the greatest risks to the security and
resilience of the United States. When applicable, funding should support deployable assets that can be used
EMPG Program Appendix | May 2022 Page H-2
anywhere in the Nation through automatic assistance and mutual aid agreements, including, but not limited
to, the Emergency Management Assistance Compact. The EMPG Program supports investments that
improve the ability of jurisdictions nationwide to:
• Prevent a threatened or an actual act of terrorism;
• Protect our citizens, residents, visitors, and assets against the greatest threats and hazards;
• Mitigate the loss of life and property by lessening the impact of future disasters;
• Respond quickly to save lives, protect property and the environment, and meet basic human needs
in the aftermath of a catastrophic incident; or
• Recover through a focus on the timely restoration, strengthening, and revitalization of
infrastructure, housing, and a sustainable economy, as well as the health, social, cultural, historic,
and environmental fabric of communities affected by a catastrophic incident.
The core capabilities contained in the Goal are highly interdependent and require the use of existing
preparedness networks and activities to improve training and exercise programs, innovation, and
appropriate administrative, finance, and logistics systems.
Implementation of the National Preparedness System
Identifying and Assessing Risk and Estimating Capability Requirements
By December 31, 2022, recipients are required to complete a THIRA/SPR that addresses all 32 core
capabilities and is compliant with Comprehensive Preparedness Guide (CPG) 201, Third Edition.
Recipients are required to submit a THIRA every three (3) years to establish a consistent baseline for
assessment. 2022 is the start of the new 3-year THIRA/SPR cycle and baseline assessment year. Specific
guidance on the requirements for each core capability is provided through technical assistance and
supplemental guidance, as some core capabilities have fewer reporting requirements than others. Recipients
must continue to respond to a series of planning-related questions as part of the THIRA/SPR process.
While the THIRA is only required every three years, jurisdictions are required to submit an SPR annually.
The submission deadline is December 31st each year (as applicable). For additional guidance on the
THIRA/SPR, please refer to Comprehensive Preparedness Guide (CPG) 201, Third Edition.
Reporting:
• In each EMPG Program recipient’s Biannual Strategy Implementation Report (BSIR), as part of
programmatic monitoring, the recipient must describe how expenditures support closing capability
gaps or sustaining capabilities identified in the THIRA/SPR process. EMPG Program recipients
will, on a project-by-project basis, check one of the following:
o Building a capability with EMPG Program funding; or
o Sustaining a capability with EMPG Program funding.
Building and Sustaining Core Capabilities
Recipients must describe how proposed EMPG Program-funded projects will close capability gaps or
sustain capabilities identified through the THIRA/SPR process, particularly SPR Step 2 (see
Comprehensive Preparedness Guide (CPG) 201, Third Edition), or other relevant information sources that
identify capability needs. See EMPG Program Work Plan section for additional guidance and
requirements.
National Incident Management System (NIMS) Implementation
EMPG Program recipients and subrecipients are required to implement NIMS. NIMS guides all levels of
government, nongovernmental organizations (NGO), and the private sector to work together to prevent,
EMPG Program Appendix | May 2022 Page H-3
protect against, mitigate, respond to, and recover from incidents. NIMS provides stakeholders across the
whole community with the shared vocabulary, systems, and processes to successfully deliver the
capabilities described in the National Preparedness System. EMPG Program recipients must use
standardized resource management concepts for resource typing, credentialing, and an inventory to
facilitate the effective identification, dispatch, deployment, tracking, and recovery of resources.
EMPG Program funds may be used for NIMS implementation; specifically, to meet the requirements
described in the NIMS Implementation Objectives for Local, State, Tribal, and Territorial Jurisdictions.
This document should be used as a guide for both identifying NIMS implementation objectives and needs
and as a tool for evaluating NIMS compliance. Additional information about NIMS implementation is
available at NIMS Implementation and Training.
Reporting:
• Recipients will answer questions in the applicable secondary NIMS assessment portion of the
Unified Reporting Tool (URT) as part of a jurisdiction’s THIRA/SPR submission. This involves
reporting on the status of the qualification system used within the jurisdiction and sub-jurisdictions,
as outlined in the EMPG Program NOFO.
• Reporting will also be through a review by the FEMA Regional NIMS Coordinators during annual
technical assistance visits with the states, tribes, and territories within their regions.
National Qualifications System (NQS) Implementation
EMPG Program recipients are encouraged to use EMPG Program funds to support NQS implementation
efforts. For FY 2022, as a post-award requirement, all recipients in the 50 states and the District of
Columbia must begin their NQS implementation efforts by achieving, or working towards achieving, the
Phase 1 objectives outlined in the table below and must, at a minimum, plan for implementation of the
Phase 2 objectives. All other jurisdictions (including territories and FY 2022 EMPG Program subrecipients)
must, at a minimum, plan for implementation of Phases 1 and 2. For all states and territories, the following
requirements shall apply:
• Only EMPG Program-funded deployable personnel, as determined by each recipient
organization, will be required to meet NQS certification requirements.
• Recipients and subrecipients will be considered in compliance with the NQS requirements as long
they are working towards implementing the NQS Implementation Objectives as outlined in the
table below.
Phase 1 NQS Implementation
Objectives for FY 2022 Example Indicators
1. Ensure that incident
workforce personnel
qualifying for a position meet
the minimum training
requirements from the Job
Title/Position Qualification
for that position.
• Official training guidance that specifies:
o Which training courses incident workforce personnel
must take;
o How long they have to complete the training after they
join the jurisdiction or organization; and,
o Frequency of refresher training.
• Minimum criteria that trainees must meet to be qualified in a
specific position.
• Issuance of Position Task Books; documenting performance
criteria for each position, include competencies, behaviors and
tasks.
The NIMS Training Program clarifies recommended training for
incident personnel (See Page 13 of the NIMS Training Program).
EMPG Program Appendix | May 2022 Page H-4
Phase 1 NQS Implementation
Objectives for FY 2022 Example Indicators
2. Use of a resource
management or qualification
tool system to track the
qualification, certification,
and credentialing of incident
workforce personnel.
Resource management systems such as:
• OneResponder, a web-based application hosted in a cloud
environment. It allows Authorities Having Jurisdiction (AHJ) to
management qualifications of personnel.
• Interagency Resource Ordering Capability (IROC), a tool to
support the interagency wildland fire community in ordering,
tracking, and managing resources in response to wildland fires
and all‐hazard incidents.
Locally hosted tools such as:
• Microsoft Excel spreadsheet
• Microsoft Access database
Phase 2 NQS Implementation
Objectives for FY 2023 Example Indicators
3. Develop organizational
qualification system
procedures, certification
program, and credentialing
standards for incident
workforce personnel in
alignment with the NIMS
Guideline for the National
Qualification System.
Procedures include:
• Establishment of a Qualification Review Board, or equivalent
review processes for incident workforce personnel
qualifications.
• Individual and team coach and evaluation processes for incident
workforce personnel qualifications.
The NIMS NQS Supplemental Guide for Qualification Review
Boards and NIMS NQS Supplemental Guide for Coaches and
Evaluators provides guidance for establishing and maintaining
these programs.
Phase 3 NQS Implementation
Objectives for FY 2024 Example Indicators
4. Design, develop and conduct
exercises in accordance with
the Homeland Security
Exercise and Evaluation
Program (HSEEP) for
incident workforce personnel.
Documentation and/or after-action reports that indicate participation
in an HSEEP sponsored exercise or real-world incident.
Reporting:
Data collection and reporting on NQS implementation will be addressed via the following:
• NIMS secondary assessment questions on the URT. This involves reporting on the status of the
qualification system used within the jurisdiction and sub-jurisdictions.
• NIMS Regional Coordinator Program Guide that allows Regional NIMS Coordinators to review
state NIMS programs.
• Review by the Regional NIMS Coordinators during annual technical assistance visits with the
states, tribes, and territories within their regions.
Logistics Planning
Distribution Management Plans
EMPG Program recipients are required to develop and maintain a Distribution Management (DM) plan as
an annex to their existing Emergency Operations Plan (EOP). Comprehensive Preparedness Guide (CPG)
101 provides guidance on the fundamentals of planning and development of Emergency Operations Plans.
EMPG Program Appendix | May 2022 Page H-5
The Distribution Management Plan Guide 2.0 (fema.gov) released in January 2022 provides information on
how to develop the DM plan annex, key DM plan components, how to review and update a DM plan, and
how FEMA reviews and evaluates the plans.
The DM plan must be reviewed by recipients on an annual basis and updated as necessary by September
30th of each calendar year. A question in the URT under the CPG 101 captures whether a jurisdiction has
developed and incorporated a DM plan in its EOP.
• The DM plan should focus on the distribution of commodities and supplies such as food, water,
generators and tarps to survivors following a disaster
• The DM plan should address strategies/plans for the following:
o Requirements Defining
o Resource Ordering
o Distribution Methods
o Inventory Management
o Staging Areas
o Transportation
o Demobilization
FEMA Regional Logistics Branch staff will work with EMPG Program recipients to provide technical
assistance during the development and maintenance of their DM plans, and to ensure all recipients have
effective DM plans capable of integrating with federal, NGOs, private sector, and state, local, tribal, and
territorial stakeholders during major disasters. Recipients should refer to the following for additional
guidance:
• Information Bulletin (IB) 442, Guidance on Distribution Management Plans for the Fiscal Year
2019 Emergency Management Performance Grants Program; and
• Distribution Management Plan Guidance found at: Planning Guides | FEMA.gov
Additional Logistics Planning Resources
FEMA recommends that EMPG Program recipients use the following resources in developing their DM
plan. To learn more about these programs and documents, or for any questions, please contact the Logistics
Section Chief from your FEMA Region.
• The Logistics Capability Assessment Tool 2 (LCAT2) Flyer: The LCAT2 Flyer provides an
overview of the LCAT2, how it is beneficial, how the LCAT process works, and how to obtain an
LCAT2.
• Points of Distribution (PODs) Training: FEMA Logistics developed a comprehensive POD
training to assist states in developing actionable emergency distribution plans and understanding
associated challenges. Additional information, including an explanatory DVD, POD guide, and
online exam, are available on the Emergency Management Institute’s (EMI) website at FEMA -
Emergency Management Institute (EMI) Course | IS-26: Guide to Points of Distribution.
• Interagency Logistics (IL) Training: This basic IL training course familiarizes participants with
the IL concepts of planning and response. The course also provides an overview of IL Partner
disaster response organizations, discusses parameters for logistics support coordination, and creates
a whole community forum to exchange the best logistics practices. Recipients may find more
information on the course by visiting the EMI website Emergency Management Institute | EMI
Courses & Schedules (fema.gov).
• Other Logistics Planning Resources: Recipients will find additional planning guidance at:
Planning Guides | FEMA.gov. Specific to logistics planning, Comprehensive Preparedness Guide
(CPG) 101, Version 2.0 provides guidance on how to incorporate logistics into EOPs. Additionally,
the Supply Chain Resilience Guide provides emergency managers with recommendations and best
EMPG Program Appendix | May 2022 Page H-6
practices on how to analyze local supply chains and work with the private sector to enhance supply
chain resilience using a five-phased approach.
Funding for Critical Emergency Supplies
Critical emergency supplies—such as shelf stable products, water, and basic medical supplies—are an
allowable expense under the EMPG Program. Each state must have FEMA’s approval of a five-year viable
inventory management plan prior to allocating grant funds for stockpiling purposes. The inventory
management five-year plan should include a distribution strategy and related sustainment costs if the grant
expenditure is over $100,000.
Reporting
Annual DM plan reviews will be reported in the Performance Progress Report (PPR) for the quarter ending
September 30 of the most recently awarded EMPG Program. Reviews that result in an update must be
submitted to the Regional Grants Division Director or Regional EMPG Program Manager for review by
regional logistics staff. The Regional Logistics Staff will review and rate the plans using the latest FEMA
Distribution Management Plan Guide 2.0.
Evacuation Planning
EMPG Program recipients should review and update their EOP in accordance with Comprehensive
Preparedness Guide (CPG) 101 v3, Developing and Maintaining Emergency Operations Plans. Recipients
are highly encouraged to include an evacuation plan or annex as part of their EOP as well as plans to
exercise and validate the evacuation plan and capabilities. At a minimum, recipients should incorporate the
National Response Framework’s Mass Evacuation Incident Annex’s planning considerations, and other
FEMA documents related to evacuation planning, when developing their own Evacuation Plan or Annex.
See National Response Framework (NRF), Third Edition (June 2016) and NRF Mass Evacuation Incident
Annex (June 2008). Additional National Preparedness resources are available at: National Preparedness
and Planning Guides. Specific to evacuation planning, the Evacuation and Shelter in Place Guidance
identifies relevant concepts, considerations, and principles that can inform jurisdictions in planning for
evacuation and/or shelter-in-place protective actions.
Disaster Housing Planning
State-Led Disaster Housing Task Force
Based on lessons learned from recent disasters, FEMA strongly encourages EMPG Program recipients to
establish a State-Led Disaster Housing Task Force (SLDHTF) plan as part of their EOP or as a standalone
document and update their plan at least once every two years.
SLDHTFs lead and coordinate state, local, private sector, and community-based actions to assess housing
impacts, identify appropriate post-disaster housing options, and establish processes for expediting post-
disaster housing delivery. SLDHTF plans should clearly identify the roles, responsibilities, composition,
and mobilization procedures for the SLDHTF, and how the SLDHTF integrates into the incident command
structure. To have a successful SLDHTF plan, FEMA encourages recipients to:
• Complete the State Housing Strategy Template; and
• Establish a State Disaster Recovery Coordinator.
State Housing Strategy Template
EMPG Program recipients are strongly encouraged to update their State Housing Strategy using the State
Housing Strategy Template as part of their EOP or as a standalone document. In addition to the State
Housing Strategy Template, recipients are encouraged to define and emphasize sheltering, short term, and
permanent housing planning.
EMPG Program Appendix | May 2022 Page H-7
The State Housing Strategy Template helps states identify priorities and document critical, jurisdiction-
specific processes and procedures to promote an efficient disaster housing mission. The template walks
recipients through the following planning considerations as seen in the table below. See the State-
Administered Direct Housing Grant Guide, July 2020 for the template and other supporting information.
State Housing Template Sections and Planning Considerations
Template Section Planning Considerations
SLDHTF Plan
Organization
Participant inclusion, approaches for various types of housing disasters, available
materials, available assistance programs, and sources for surge staffing
Housing
Background
Identifying a jurisdiction’s current housing situation, priorities, capabilities,
challenges, and known risks
Sheltering Phase
Strategy
Identifying planning leads, current resources, timeline, key partners, cross-
jurisdictional agreements, and other risks
Interim Housing
Strategy
Identifying planning leads, current resources and capabilities, known areas of
difficulty, key partners, relocation strategies, and risks
Permanent
Housing Strategy
Identifying planning leads, long-term housing needs and prioritizations, current
resources and capabilities, known areas of implementation challenges, relocation
strategies, and risks
Pre-Disaster
Activities
Creating communication plans, survivor transition plans, mitigation plans, and
program closeout goals
Post-Disaster
Activities
Prioritizing disaster housing recovery activities, creating timelines for project
completion, documenting planned actions for assessing the availability of
affordable housing resources and expediting the delivery of housing by expediting
permitting and waiver processes, establishing an information sharing method,
creating an Environmental Planning and Historic Preservation (EHP) strategy,
identifying potential locations for Manufactured Housing Units and Recreational
Vehicles, and identifying available federal disaster housing assistance
State-Administered Direct Housing Implementation
FEMA encourages states to develop the capacity to administer FEMA Direct Housing Assistance through a
reimbursable Inter-Governmental Service Agreement (IGSA). Under this arrangement, FEMA determines
disaster survivors’ eligibility for specific direct housing options and makes all determinations regarding
continuing eligibility, appeals, and eligibility terminations. FEMA also monitors the state’s administration
of approved Direct Housing Options to ensure compliance with federal environmental, historic
preservation, and floodplain management requirements as well as program conditions specified within the
IGSA. States that choose to administer Direct Housing Assistance through an IGSA are required to develop
a Direct Housing Administrative Plan and are encouraged to establish pre-placed contract to support the
delivery of direct housing. Any contracts for this work would need to comply with the federal procurement
requirements at 2 C.F.R. §§ 200.317-200.327. For more information, regarding Direct Housing Assistance,
please visit Chapter 5 of the Individuals and Households Program Unified Guidance and Chapter 3 of the
Individual Assistance Program and Policy Guide (IAPPG).
Disaster Housing Exercises
Recipients are encouraged to exercise and validate their long-term sheltering and housing stabilization plans
as part of an existing exercise program. This includes:
EMPG Program Appendix | May 2022 Page H-8
• Validating the organizational structure of the Housing Task Force and internal readiness
capabilities to address post-disaster housing recovery issues or administer FEMA Direct Housing
Assistance under an IGSA
• Validating disaster housing communication plans and procedures that coordinate and integrate the
activities and information generated by internal/external partners
• Validating data systems, security, and exchange protocols
• Validating planned actions and milestones transitioning from emergency sheltering to temporary
housing to permanent housing and long-term recovery
Additional Disaster Housing Planning Resources
Recipients are encouraged to review the planning guidance available at Planning Guides. The Planning
Guides page includes: Planning Considerations: Disaster Housing Guidance for State, Local, Tribal and
Territorial Partners (May 2020), which supplements Comprehensive Preparedness Guide (CPG) 101:
Developing and Maintaining Emergency Operations Plans. It provides guidance on national housing
priorities, types of housing, key considerations and housing-specific planning recommendations for state,
local, tribal and territorial (SLTT) jurisdictions to use, in conjunction with the Six-Step Planning Process
described in CPG 101, to develop or improve disaster housing plans.
State Disaster Recovery Coordinator
The Pre-Disaster Recovery Planning Guide helps states prepare for recovery by developing pre-disaster
recovery plans that follow a process to engage members of the whole community, develop recovery
capabilities, and create an organizational framework for recovery efforts.
FEMA strongly recommends that EMPG Program recipients include pre-disaster recovery planning as part
of their State Readiness and Preparedness efforts by establishing a State Disaster Recovery Coordinator
(SDRC). An effective pre-disaster recovery plan and process is crucial to help recipients prepare for major
disaster incidents and recover effectively. Recipients are encouraged to use the Pre-Disaster Recovery
Planning Guide to help inform their identification and establishment of a SDRC. The SDRC position should
be included in the State Administrative Plan with the following responsibilities:
• Development of the pre-disaster recovery plan, including state-level leadership and structure,
formation of communication channels, multi-agency coordination, and building whole-community
partnerships to support recovery efforts.
• Set the stage for necessary strategic, operational, and tactical post-disaster planning, actions, and
processes.
• Maximize impact of federal, private sector, and nongovernmental dollars to enable recovery and
resilience.
• Accelerate the delivery of resources, including funding and technical assistance, to disaster-
impacted communities.
• Enable state leadership to better organize and identify gaps in the state’s recovery capabilities.
Disaster Financial Management Policies and Procedures
Lessons learned from recent hurricane seasons and wildfires demonstrate the need for impacted
jurisdictions to improve their ability to immediately track and account for disaster costs. Disaster financial
management includes policies and procedures that work to recover expenses pertaining to damage,
emergency protective measures, and debris management during and after a disaster. These policies and
procedures include, but are not limited to, those supporting eligible contract costs and force account labor,
materials, and equipment.
State Administrative Plan
EMPG Program Appendix | May 2022 Page H-9
FEMA strongly recommends that EMPG Program recipients include disaster financial management
planning as part of their State Administrative Plan. An effective disaster financial management plan and
process is crucial to help recipients prepare for declarations of emergencies or major disasters and plan for
reimbursement. The table below details the processes that should be included in the State Administrative
Plan and recommendations on where they should be placed.
State Administrative Plan Guidance
State Administrative Plan
Section Recommendations Processes
• Section V Part D: Project
Funding and Reimbursement
• Section V Part G: Records
and Reports
• A process to ensure subrecipients are tracking and
documenting disaster costs necessary for federal
reimbursement, such as receipts, invoices, procurement
documents, contracts, and insurance coverage/claims
• Section V Part D: Project
Funding and Reimbursement
• Section V Part G: Records
and Reports
• A process to document disaster cost operations such as labor,
equipment, and materials that are allowable under federal
requirements
• Section V Part D: Project
Funding and Reimbursement
• A process to ensure that subrecipients are not receiving a
duplication in benefits
• Section IV Part B:
Organization and Staffing
• A process to ensure pre-disaster contracts and procurement
strategies are in place, if necessary
Additionally, recipients are encouraged to use EMPG Program funds for training that develops, delivers,
and exercises disaster financial management procedures.
Disaster Financial Management Resources
Recipients are encouraged to use the following resources to inform their disaster financial management
planning efforts:
• State Administrative Plan Template: Recipients are recommended to use the State
Administrative Plan template found on FEMA’s Public Assistance webpage to inform their
planning efforts. The template includes example structure and content as a model for states to create
own Administrative Plan.
• Public Assistance Program and Policy Guide: The Public Assistance Program and Policy Guide
(PAPPG) combines all Public Assistance policy into a single volume and provides an overview of
the PA program implementation process.
• Public Assistance Frequently Asked Questions and Guidance: Recipients are encouraged to
view the Public Assistance Frequently Asked Questions and guidance found on the Public
Assistance webpage to assist with disaster financial management planning efforts. The webpage
provides information pertaining to documentation, Public Assistance grant funding eligibility, and
hazard mitigation and can be found at Public Assistance Fact Sheets, Job Aids, and FAQs.
• Office of Inspector General (OIG) Audit Tips: Recipients are recommended to consult the DHS
OIG report, Audit Tips for Managing Disaster-Related Project Costs (OIG-17-120-D) for further
assistance in documenting and accounting for disaster-related costs. This report is informed by OIG
audit findings and can assist recipients in addressing issues that are frequent findings in disaster-
related audits.
• Disaster Financial Management Guide: The Disaster Financial Management Guide provides
guidance for state, local, tribal, and territorial partners on establishing and implementing sound
disaster financial management practices.
EMPG Program Appendix | May 2022 Page H-10
• Procurement Disaster Assistance Team (PDAT): The PDAT provides training and other
resources to assist grant recipients in their efforts to comply with federal procurement standards.
See Contracting with Federal Funds for Goods and Services Before, During and After Disasters |
FEMA.gov for additional information.
Training and Exercises
Integrated Preparedness Plan (IPP)
Recipients are expected to engage senior leaders and other whole community stakeholders to identify
preparedness priorities specific to training and exercise needs, which will guide development of a
state/territory multi-year IPP. Similar to the EMPG Program Work Plan development process, these
priorities should be informed by various factors, including jurisdiction-specific threats and hazards (i.e., the
THIRA); areas for improvement identified by real-world events and exercises (i.e., AARs); external
requirements such as state or national preparedness reports (i.e., SPRs), homeland security policy, and
industry reports; and accreditation standards, regulations, or legislative requirements. Recipients must
document these priorities, in conjunction with the Work Plan development process, and use them to deploy
a schedule of preparedness events and activities in the IPP. Information related to IPPs and Integrated
Preparedness Planning Workshops (IPPWs) can be found on the HSEEP website at Homeland Security
Exercise and Evaluation Program and FEMA Preparedness Toolkit.
Recipients should ensure that their EMPG Program Work Plans and IPPs align with and are complementary
to one another and are used in tandem to support shared priorities for building and sustaining the
state/territory’s preparedness capabilities. Recipients should use the same shared set of priorities in both
their IPP and EMPG Program Work Plan, so that EMPG Program investments and projects help recipients
implement the planning, training, and exercise activities in their IPPs and advance their IPP priorities. To
this end, recipients should develop their IPPs and EMPG Program Work Plans together to create a planned,
organized, and methodical approach for closing capability gaps over multiple years. This will help ensure
that priorities for both the IPP and EMPG Program Work Plan are based on closing capability gaps
documented in their THIRA/SPR and other relevant sources of information. For example, if a recipient
selects Logistics and Distribution Management, Resilient Communications, and Housing as its priorities for
its EMPG Program Work Plan, those should also be priorities in its IPP. Additionally, IPPs should include
all planning, training, and exercise activities funded by the EMPG Program and included in EMPG Program
Work Plans, as well as activities funded by other sources. This will ensure that recipients’ preparedness
projects, investments, and activities are concentrated, focused, and oriented towards closing gaps related to
their top priorities, regardless of funding source.
Validating Capabilities through Exercises
All recipients are required to develop and maintain a progressive exercise program consistent with HSEEP
guidance in support of the National Exercise Program (NEP). The NEP serves as the principal exercise
mechanism for examining national preparedness and measuring readiness. The NEP is a two-year cycle of
exercises across the nation that validates capabilities in all preparedness mission areas. The two-year NEP
cycle is guided by Principals’ Strategic Priorities, established by the National Security Council and
informed by preparedness data from jurisdictions across the Nation. See Exercises for additional
information.
While there are no minimum exercise requirements, FEMA Regional Administrators and State Emergency
Management Directors will negotiate an exercise program that addresses the priorities and capability gaps
identified through the collaborative work plan development process. These exercises must be included in
the FY 2022 EMPG Program Work Plan submitted for regional approval and should also be included in the
state/territory’s IPP. See the EMPG Program Work Plan section for additional guidance.
EMPG Program Appendix | May 2022 Page H-11
The NEP provides exercise sponsors the opportunity to receive exercise design and delivery assistance,
tools and resources, enhanced coordination, and the ability to directly influence and inform policy and
preparedness programs. If you have any questions or would like to request assistance through the NEP,
please visit the NEP website or reach out to the NEP directly at NEP@fema.dhs.gov.
Reporting
• All EMPG Program-funded exercise activities must be captured in the approved EMPG Program
Work Plan.
• EMPG Program-funded exercise costs in the Work Plan can include costs to plan, conduct and
evaluate the exercise (e.g., planning, materials, props, contractual services for conducting the
exercise, AAR and Improvement Plan [IP], etc.)
• All EMPG Program-funded exercise activities must be reported quarterly. To simplify reporting, it
is recommended that recipients submit an updated Exercise Data Table from the FY 2022 EMPG
Program Work Plan Template as an attachment to the quarterly PPR. For those recipients who
choose not to use the FY 2022 EMPG Program Work Plan Template, the data and information
found in the Exercise Data Table must still be submitted (in any chosen format) as an attachment to
the PPR.
• EMPG Program-funded personnel costs associated with exercises are not required in the FY 2022
EMPG Program Work Plan Template for application or reporting purposes.
• Recipients must have a current multi-year IPP that identifies preparedness priorities and activities.
The current multi-year IPP must be submitted to hseep@fema.dhs.gov and the Regional EMPG
Program Manager before January 31st of each year.
• Recipients are encouraged to enter their exercise information into the Preparedness Toolkit at
FEMA Preparedness Toolkit.
• Recipients must submit AAR/IPs to hseep@fema.dhs.gov and copy their Regional EMPG Program
Manager and indicate which fiscal year’s funds were used (if applicable).
• Submission of AAR/IPs must take place within 90 days following completion of the single exercise
or progressive series.
o Recipients are encouraged to submit AAR/IPs reflecting tabletop exercises that validate
critical plans or those reflecting large-scale functional or full-scale exercises that took place
at the state, territorial, tribal, or regional level. Recipients are discouraged from submitting
AAR/IPs specific to local jurisdictions that reflect drills.
o If a state, territory, or local jurisdiction has experienced a major disaster and they would
like to request exemptions for a scheduled exercise, the recipient should send this request to
its assigned Regional EMPG Program Manager through the quarterly PPR. Exemptions
will be reviewed by the Region on a case-by-case basis.
o Recipients can access a sample AAR/IP template at Preparedness Toolkit Improvement
Planning Templates.
Training
Similar to the exercise guidance above, training activities should align to a current, multi-year IPP
developed through an annual IPPW and build from training gaps identified in the THIRA/SPR and work
plan development process. Further guidance concerning the IPP and the IPPW can be found at HSEEP
Resources - Preparedness Toolkit.
Training should foster the development of a community-oriented approach to emergency management that
emphasizes engagement at the community level, strengthens best practices, and provides a path toward
building sustainable resilience, all of which is included in the curriculum of the EMI Basic Academy. The
EMI Basic Academy provides a foundational education in emergency management as a way for emergency
managers to begin or advance their career. The goal of the Basic Academy is to support the early careers of
EMPG Program Appendix | May 2022 Page H-12
emergency managers through a training experience combining knowledge of all fundamental systems,
concepts, and practices of cutting-edge emergency management.
EMPG Program funds used for training should support the nationwide implementation of NIMS. The NIMS
Training Program establishes a national curriculum for NIMS and provides information on NIMS courses.
Recipients are encouraged to place emphasis on the core competencies as defined in the NIMS Training
Program. NIMS is also included in the curriculum of the EMI Basic Academy. The NIMS Training
Program can be found at NIMS Implementation and Training.
All EMPG Program-funded personnel are expected to be trained emergency managers (see NQS
Implementation section). All EMPG Program-funded personnel must complete either the Independent
Study courses identified in the Professional Development Series or the National Emergency Management
Basic Academy delivered either by EMI or at a sponsored state, local, tribal, territorial, regional, or other
designated location. Further information on the National Emergency Management Basic Academy and the
Emergency Management Professional Program can be found at: EMI EMPP. A complete list of
Independent Study Program Courses may be found at EMI Independent Study.
In addition to training activities aligned to and addressed in the IPP, all EMPG Program-funded personnel
(including full- and part-time SLTT recipients and subrecipients) must complete the following training
requirements and record proof of completion:
1) NIMS Training, Independent Study (IS)-100 (any version), IS-200 (any version), IS-700 (any
version), and IS-800 (any version)4, and;
2) Professional Development Series (PDS) or the Emergency Management Professionals Program
(EMPP) Basic Academy listed in the chart below.
PDS
Professional Development Series OR Basic Academy
Basic Academy Pre-requisites and Courses
IS-120.a: An Introduction to Exercises OR IS-100 (any version): Introduction to the
Incident Command System
IS-230.d: Fundamentals of Emergency
Management OR IS-700 (any version): National Incident
Management System (NIMS)-An Introduction
IS-235.b: Emergency Planning OR IS-800 (any version): National Response
Framework, An Introduction
IS-240.b: Leadership and Influence OR IS-230.d: Fundamentals of Emergency
Management
IS-241.b: Decision Making and
Problem Solving OR E/L101: Foundations of Emergency
Management
IS-242.b: Effective Communication OR E/L102: Science of Disasters
IS-244.b: Developing and Managing
Volunteers OR E/L103: Planning Emergency Operations
IS-244.b: Developing and Managing
Volunteers OR E/L104: Exercise Design
IS-244.b: Developing and Managing
Volunteers OR E/L105: Public Information & Warning
4 NIMS training courses IS-100, IS-200, IS-700, and IS-800 only need to be taken once to fulfill requirements. Also,
previous versions of the IS courses are still considered as meeting the NIMS training requirement.
EMPG Program Appendix | May 2022 Page H-13
The EMI Basic Academy provides this foundational Emergency Management education. To ensure the
professional development of the emergency management workforce, the recipients must ensure a routine
capabilities assessment is accomplished and an IPP is developed and implemented.
Additional Training Information
Per FEMA Grant Programs Directorate Information Bulletin 432, Review and Approval Requirements for
Training Courses Funded Through Preparedness Grants, issued on July 19, 2018, states, territories, tribal
entities, and high-risk urban areas are no longer required to request approval from FEMA for personnel to
attend non-DHS FEMA training as long as the training is coordinated with and approved by the state,
territory, tribal, or high-risk urban area Training Point of Contact (TPOC) and falls within the FEMA
mission scope and the jurisdiction’s EOP.
FEMA will conduct periodic reviews of all state, territory, and urban area training funded by FEMA. These
reviews may include requests for all course materials and physical observation of, or participation in, the
funded training. If these reviews determine that courses are outside the scope of this guidance, recipients
will be asked to repay grant funds expended in support of those efforts.
For further information on developing courses using the instructional design methodology and tools that can
facilitate the process, State Administrative Agencies (SAAs), and TPOCs are encouraged to review the
National Training and Education Division (NTED) Training Resource and Development Center website at
First Responder Training Resource and Development Center.
FEMA’s National Preparedness Course Catalog
This online searchable catalog features a compilation of courses managed by the three primary FEMA
training organizations: the Center for Domestic Preparedness, EMI, and NTED. The catalog features a wide
range of course topics in multiple delivery modes FEMA for federal, state, local, territorial, and tribal
audiences. The catalog is located at First Responder Training and Education Division.
Reporting
• All EMPG Program-funded training activities must be captured in the approved EMPG Program
Work Plan and should be included in the IPP. This includes training for which the only expenses
are for overtime and/or backfill costs associated with emergency management personnel attending
the training.
• All EMPG Program-funded training activities must be reported quarterly. To simplify reporting, it
is recommended the recipient submit an updated Training Data Table from the FY 2022 EMPG
Program Work Plan Template as an attachment to the quarterly PPR. For those recipients who
choose not to use the FY 2022 EMPG Program Work Plan Template, the data and information
found in the Training Data Table must still be submitted (in any chosen format) as an attachment to
the PPR.
• Recipients must report their NIMS implementation status of their jurisdiction and sub-jurisdictions,
including the training of personnel, in the applicable secondary NIMS assessment portion of the
URT as part of their THIRA/SPR submission.
• Recipients must maintain proof of completion of training requirements.
• Training Information Reporting System (“Web Forms”): Web Forms is an electronic data
management system built to assist SAA TPOCs and federal agencies to submit non-NTED training
courses for inclusion in the State/Federal-Sponsored Course Catalog. The information collected is
used in a two-step review process to ensure that the training programs adhere to the EMPG
Program’s intent and the course content is sound and current. While reporting training activities
through Web Forms is not required under the EMPG Program, the system remains available and
EMPG Program Appendix | May 2022 Page H-14
can be accessed through the Web-Forms section of the FEMA National Preparedness Course
Catalog to support recipients in their own tracking of training deliveries.
Reviewing and Updating Planning Products
Based on the applicant’s current THIRA/SPR, capability levels, and resources, plans should be reviewed on
an annual basis to determine if they remain relevant or need to be updated. This review should be based on
a current THIRA/SPR and utilize information gathered during the capability validation process. These
reviews will provide a means to determine priorities, direct preparedness actions, and calibrate goals and
objectives.
Additional Considerations
Strengthening Governance Integration
FEMA preparedness grant programs are intended to support the core capabilities across the five mission
areas of Prevention, Protection, Mitigation, Response, and Recovery that are necessary to prepare for
incidents that pose the greatest risk to the Nation’s security. Each program reflects the Department’s intent
to build and sustain an integrated network of national capabilities across all levels of government and the
whole community. Disparate governance structures must be integrated and refined to ensure resources are
targeted to support the most critical needs of a community based on risk-driven, capabilities-based
planning. Strong and inclusive governance systems better ensure that disparate funding streams are
coordinated and applied for maximum impact.
FEMA requires that all governance processes that guide the allocation of preparedness grant funds adhere to
the following guiding principles:
• Coordination of Investments: Resources must be allocated to address the most critical capability
needs as identified in the SPR and coordinated among affected preparedness stakeholders, including
appropriate representatives of at-risk, underserved communities.
• Transparency: Stakeholders must be provided visibility on how preparedness grant funds are
allocated and distributed, and for what purpose.
• Substantive Local Involvement: The tools and processes that are used to inform the critical
priorities, which FEMA grants support, must include local government representatives. At the state
and regional levels, local risk assessments must be included in the overarching analysis to ensure
that all threats and hazards are accounted for. Primary focus should be on the needs of socially
vulnerable, underserved populations and ensuring equity for those most at risk relative to disaster
preparedness, response, and recovery.
• Accountability: FEMA recognizes that unique preparedness gaps exist at the local level. Grant
recipients are responsible for ensuring the effective use of funds to address those gaps and for
maintaining and sustaining existing capabilities, particularly when it comes to serving the needs of
at-risk, underserved communities.
• Support of Regional Coordination: Inter/intra-state partnerships and dependencies at the state and
regional levels, including those within metropolitan areas, must be recognized.
Program Performance Reporting Requirements
Performance Progress Reports (PPR)
Recipients are responsible for providing performance reports to FEMA on a quarterly basis. As explained in
the Standardized Programmatic Reporting section below, the quarterly PPRs must be based on the
approved EMPG Program Work Plan and are due no later than 30 days after the end of the quarter.
Although not mandatory, recipients are encouraged to use the updated FY 2022 EMPG Program Work Plan
Template – specifically the Implementation Schedule, Training Data Table, and Exercise Data Table – to
EMPG Program Appendix | May 2022 Page H-15
report on the status of planned project activities, any risks that may affect project progress or success, and
updates to project schedules. The PPR (in the form of an updated Work Plan) shall be submitted in ND
Grants. See EMPG Program Work Plan section for additional guidance.
Programmatic Reporting Periods and Due Dates
The following reporting periods and due dates apply for the PPR:
Reporting Period Report Due Date
October 1 – December 31 January 30
January 1 – March 31 April 30
April 1 – June 30 July 30
July 1 – September 30 October 30
Standardized Programmatic Reporting for the EMPG Program
The FY 2022 EMPG Program Work Plan Template has been modified to standardize data collection, which
enables improved analysis and reporting. The EMPG Program Work Plan includes ten components:
1) Grant Investment Strategy
2) Grant Activities Outline
3) Detailed Budget – Excluding Management and Administrative (M&A)
4) Budget Narrative – Excluding M&A
5) Detailed Budget – M&A Only
6) Budget Narrative – M&A Only
7) EMPG Program Summary
8) Implementation Schedule
9) Training Data Table
10) Exercise Data Table
Although use of the FY 2022 EMPG Program Work Plan Template is not mandatory (see EMPG Program
Work Plan section), baseline data on personnel, training, and exercises, as well as the information included
Grant Activities Outline and Implementation Schedule, must be provided in the EMPG Program Work Plan
at the time of application regardless of the chosen work plan format.
The status of all EMPG Program-funded plans, training, and exercise activities must be reported quarterly
as part of the PPR. To facilitate reporting, recipients are encouraged to submit an updated Implementation
Schedule, Training Data Table, and Exercise Data Table from the FY 2022 EMPG Program Work Plan
Template as an attachment to the quarterly PPR. Recipients who choose not to use the FY 2022 EMPG
Program Work Plan Template must still provide the updated data and information included in the
Implementation Schedule, Training Data Table, and Exercise Data Table, but may use a different format for
reporting that information in their PPR submission.
EMPG Program Appendix | May 2022 Page H-16
EMPG Program Funding Guidelines
Allowable Costs
Management and Administration (M&A)
M&A activities are those defined as directly relating to the management and administration of EMPG
Program funds, such as financial management, reporting, and program and financial monitoring. Some
examples of M&A costs include grants management training for M&A staff, equipment and supplies for
M&A staff to administer the EMPG Program grant, travel costs for M&A staff to attend conferences or
training related to the EMPG Program, travel costs for the M&A staff to conduct subrecipient monitoring,
contractual services to support the M&A staff with M&A activities, and auditing costs related to the grant
award to the extent required or permitted by statute or 2 C.F.R. Part 200. Characteristics of M&A expenses
can include the following: 1) direct costs that are incurred to administer a particular Federal award; 2)
identifiable and unique to each Federal award; 3) charged based on the activity performed for that particular
Federal award; and 4) not duplicative of the same costs that are included in the approved Indirect Cost Rate
Agreement, if applicable. It should be noted that salaries of state and local emergency managers are not
typically categorized as M&A, unless the state or local Emergency Management Agency (EMA) chooses to
assign personnel to specific M&A activities. In this case, personnel and fringe benefits for M&A is
allowable.
If the SAA is not the EMA, the SAA is not eligible to retain funds for M&A. M&A costs are allowable for
both state and local-level EMAs. The state EMA may use up to 5% of the EMPG Program award for M&A
purposes. In addition, local EMAs may retain and use up to 5% of the amount received from the state for
local M&A purposes.
Indirect Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Per 2 C.F.R. Part 200, Appendix VII, paragraph D.1.b, state and local
governments are not permitted to use the de minimus rate without seeking and receiving FEMA’s approval
of a case-by-case exception. State and local governments who do not have a current negotiated indirect cost
rate agreement (including a provisional rate) and wish to request the case-by-case exception to use the de
minimis rate should reach out to their FEMA Grants Management Specialist for further instructions.
Applicants who wish to use a cost allocation plan in lieu of an indirect cost rate must also reach out to the
FEMA Grants Management Specialist for further instructions. Post-award requests to charge indirect costs
will be considered on a case-by-case basis and based upon the submission of an agreement or proposal as
discussed above or based upon the de minimus rate or cost allocation plan, as applicable.
Unrecovered Indirect Costs
In accordance with 2 C.F.R. § 200.306(c) “[u]nrecovered indirect costs, including indirect costs on cost
sharing or matching may be included as part of cost sharing or matching only with the prior approval of the
Federal awarding agency. Unrecovered indirect cost means the difference between the amount charged to
the Federal award and the amount which could have been charged to the Federal award under the non-
Federal entity’s approved negotiated indirect cost rate.” Therefore, unrecovered indirect costs may be
applied to meet cost share requirements of the EMPG Program grant with the approval of the Regional
Grants Division. To meet the cost sharing requirements, the recipient’s indirect costs contributions must be
EMPG Program Appendix | May 2022 Page H-17
verifiable, reasonable, allocable, necessary, and otherwise allowable under the grant program, and in
compliance with all applicable Federal requirements and regulations.
Whole Community Preparedness
EMPG Program recipients should engage with the whole community to advance community and individual
preparedness and to work as a nation to build and sustain resilience. Recipients should consider the three
goals of the 2022-2026 FEMA Strategic Plan in their program design and delivery. Recipients should
integrate program design and delivery practices that ensure representation and services for under-
represented diverse populations that may be more impacted by disasters including children, seniors,
individuals with disabilities or other access and functional needs, individuals with diverse culture and
language use, individuals with lower economic capacity, and other underserved populations.
Individual preparedness should be coordinated by an integrated body of government and nongovernmental
representatives as well, including but not limited to, elected officials, the private sector (especially privately
owned critical infrastructure), private nonprofits, nongovernmental organizations (including faith-based,
community-based, and voluntary organizations), advocacy groups for under-represented diverse populations
that may be more impacted by disasters including children, seniors, individuals with disabilities or other
access and functional needs, individuals with diverse culture and language use, individuals with lower
economic capacity, and other underserved populations. By engaging these stakeholders, EMPG Program
recipients can help FEMA develop and promote a suite of well-targeted solutions for individuals and
communities to adopt. Recipients should coordinate preparedness initiatives with FEMA and whole
community partners to efficiently apply federal funding to reach the goal of individual and community
resilience.
The following preparedness programs are allowable expenses and resources:
• Community Emergency Response Team (CERT) programs, which educate volunteers about
disaster preparedness for the hazards that may impact their area and train them in basic disaster
response skills, such as fire safety, light search and rescue, team organization, and disaster medical
operations. CERT offers a consistent, nationwide approach to volunteer training and organization
that professional responders can rely on during disaster situations, allowing them to focus on more
complex tasks.
• Financial Preparedness Activities that encourage and assist Americans in preparing for the true
cost of disasters. Allowable activities include encouraging emergency savings, promoting home and
renter’s insurance, and promoting flood insurance for individuals and families. Partnerships with
local financial wellness organizations such as credit unions, financial counselors, community banks,
and others that reach a variety of audiences are encouraged.
• Preparedness of Community-Based Organizations that serve as a critical safety net for
Americans disproportionately impacted by disasters. Examples of community-based organizations
include but are not limited to food banks, food pantries, homeless shelters, school readiness and
after school centers, adult day care centers, job training centers, legal assistance centers, and
cultural centers. Allowable activities include Whole Community exercises, trainings, and activities
focused on staff preparedness, information sharing with clients and government, and continuity of
essential functions in the event of an emergency.
• Youth Preparedness Resources are available on Ready Kids. Bolstering youth preparedness
across the nation is a priority for FEMA as the Agency works with state, local, tribal, and territorial
partners to create a culture of preparedness in the United States. Information on youth-centric
educational curricula, games, planning materials, and other relevant resources can be found at
Ready Kids. Furthermore, FEMA’s Individual and Community Preparedness Division and regional-
based Community Preparedness Officers are available to provide grant recipients with guidance and
EMPG Program Appendix | May 2022 Page H-18
assistance. Please email FEMA-Prepare@fema.dhs.gov to contact one of the Agency’s subject
matter experts.
The following are examples of youth preparedness activities that recipients are encouraged to
undertake as allowable costs:
o Reach out to a local school board or elementary school to encourage the adoption of the
Student Tools for Emergency Planning (STEP) curriculum. STEP is a classroom-based
emergency preparedness curriculum for 4th- and 5th-graders in an easy, ready-to-teach
format. Students will learn about disasters, emergencies, and hazards, and how to create a
disaster supply kit and family emergency communication plan. An overview of the STEP
program along with the instructor guide and student activity book is available at Ready
STEP.
o Sponsor the creation of a Teen CERT in your jurisdiction. The CERT Program is a national
program of volunteers trained in disaster preparedness and emergency response. Volunteers
come from all ages and all walks of life, including teenagers. Additional information,
including a step-by-step guide on how to start a Teen CERT, is available at Ready Teen
CERT.
The following tools are available to order from FEMA’s warehouse free of charge:
o “Prepare with Pedro” is a joint product of FEMA and the American Red Cross. The
“Prepare with Pedro: Disaster Preparedness Activity Book” is designed to teach young
children and their families about how to stay safe during disasters and emergencies. The
book follows Pedro around the United States and offers safety advice through crosswords,
coloring pages, matching games, and more. Additional information, including an ordering
form, is available at Ready - Prepare with Pedro.
o The Ready 2 Help card game is a fun way for kids to learn how to respond to emergencies
by working with friends and using skills that will help in a real emergency. Ready 2 Help
teaches five simple steps to stay safe and make a difference until help arrives:
• Stay Safe
• Stay Calm
• Get Help
• Give Info
• Give Care
Ready 2 Help is designed for children ages 8 and up. Additional information, including an
ordering form, is available at Ready 2 Help.
Planning
Planning spans all five mission areas of the Goal and provides a methodical way to engage the whole
community in the development of a strategic, operational, and/or community-based approach to
preparedness. EMPG Program funds may be used to develop or enhance emergency management planning
activities. Some examples include:
Emergency Operations Plan
• Maintaining a current EOP that is aligned with guidelines set out in Comprehensive Preparedness
Guide (CPG) 101: Developing and Maintaining Emergency Operations Plans
• Modifying existing incident management and emergency operations plans
• Developing/enhancing large-scale and catastrophic event incident plans
Communications Plans
• Developing and updating Statewide Communication Interoperability Plans
EMPG Program Appendix | May 2022 Page H-19
• Developing and updating Tactical Interoperability Communications Plans
Administrative Plans
• Developing/enhancing financial and administrative procedures for use before, during, and after
disaster events in support of a comprehensive emergency management program
Whole Community Engagement/Planning
• Developing or enhancing mutual aid agreements/compacts, including required membership in
EMAC
• Developing/enhancing emergency operations plans to integrate citizen/volunteer and other Non-
Governmental Organization (NGO) resources and participation
• Integrating program design and delivery practices that ensure representation and services for under-
represented, diverse populations that may be more impacted by disasters, including children,
seniors, individuals with disabilities or other access and functional needs, individuals with diverse
culture and language use, individuals with lower economic capacity, and other underserved
populations.
Resource Management Planning
• Developing/enhancing logistics and resource management plans
• Developing/enhancing volunteer and/or donations management plans
Shelter and Evacuation Planning
• Developing/enhancing sheltering and evacuation plans, including plans for alerts/warning, crisis
communications, pre-positioning of equipment for areas potentially impacted by mass evacuations,
and re-entry
Recovery Planning
• Disaster housing planning, such as creating/supporting a state disaster housing task force and
developing/enhancing state disaster housing plans
• Pre-event response, recovery, and mitigation plans in coordination with state, local, and tribal
governments
• Developing/enhancing other response and recovery plans
Developing recovery plans and preparedness programs consistent with the principles and guidance
in the National Disaster Recovery Framework (NDRF) that will provide the foundation for recovery
programs and whole community partnerships. Preparedness and pre-disaster planning were given
special attention within the NDRF with specific guidance: Planning for a Successful Disaster
Recovery (pages 63-70). For more information on the NDRF see National Disaster Recovery
Framework.
Continuity Planning
Continuity planning and operations are an inherent element of each core capability. Continuity operations
increase resilience and the probability that organizations can perform essential functions. FEMA develops
and promulgates Federal Continuity Directives (FCDs) to establish continuity program and planning
requirements for executive departments and agencies and Continuity Guidance Circulars (CGCs) for SLTT
governments, non-governmental organizations, and private sector critical infrastructure owners and
operators. This direction and guidance assist in developing capabilities for continuing the essential functions
of federal, state, local, tribal, territorial governmental entities as well as the public/private critical
infrastructure owners, operators, and regulators enabling them.
Presidential Policy 40, FCD 1, FCD 2, CGC 1, and CGC 2 outline the overarching continuity requirements
and guidance for organizations and provide guidance, methodology, and checklists. For additional
information on continuity programs, guidance, directives, and available technical assistance, visit
EMPG Program Appendix | May 2022 Page H-20
Continuity Resources and Technical Assistance and National Continuity Programs.
Allowable continuity planning activities include the development of the following:
• Continuity of operations and Continuity of Government planning products for the continuance of
essential functions and associated leadership;
• Risk-based needs assessments based on the THIRA to inform risk mitigation efforts to ensure the
continuity of essential functions and associated leadership; and
• Public and private sector outreach and messaging regarding continuity resilience benefits and
strategies.
Organization
Per the Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. No. 93-288, as amended,
(42 U.S.C. §§ 5121-5207), EMPG Program funds may be used for all-hazards emergency management
operations, staffing, and other day-to-day activities in support of emergency management, including hazard
mitigation staffing of the State Hazard Mitigation Officer position; staffing CERT and Citizen Corps
positions at the state and local levels to promote whole community engagement in all phases of emergency
management; performing closeout activities on FEMA disaster assistance grants; staffing permanent
technical advisors on children’s needs at the state, local, tribal, and territorial levels; and supporting fusion
center analysts who are directly involved in all-hazards preparedness activities as defined by the Stafford
Act. Proposed staffing activities should be linked to accomplishing the activities outlined in the EMPG
Program Work Plan. Recipients are encouraged to fund at least one dedicated Planner, Training Officer, and
Exercise Officer. Personnel costs, including salary, overtime, compensatory time off, and associated fringe
benefits, are allowable EMPG Program costs and must comply with 2 C.F.R. Part 200, Subpart E – Cost
Principles.
Federal (and Mutual Aid) Emergency Response Official (F/ERO) Credentialing and
Validation
The following costs related to F/ERO credentialing and validation are allowable under the EMPG Program:
• Working group meetings and conferences relating to emergency responder credentialing and
validation;
• Compiling data to enter into an emergency responder repository;
• Coordinating with other state, local, territorial, and tribal partners to ensure interoperability among
existing and planned credentialing and validation systems and equipment; and
• Planning to incorporate emergency responder identity and credential validation into training and
exercises.
Equipment
Allowable equipment categories for the EMPG Program are listed in the Authorized Equipment List (AEL).
Unless otherwise stated, equipment must meet all mandatory regulatory and/or FEMA-adopted standards to
be eligible for purchase using these funds. In addition, agencies will be responsible for obtaining and
maintaining all necessary certifications and licenses for the requested equipment. Allowable equipment
includes equipment from the following AEL categories:
• Personal Protective Equipment (Category 1)
• Information Technology (Category 4)
• Cybersecurity Enhancement Equipment (Category 5)
• Interoperable Communications Equipment (Category 6)
• Detection Equipment (Category 7)
EMPG Program Appendix | May 2022 Page H-21
• Power Equipment (Category 10)
• Chemical, Biological, Radiological, Nuclear, and Explosive (CBRNE) Reference Materials
(Category 11)
• CBRNE Incident Response Vehicles (Category 12)
• Physical Security Enhancement Equipment (Category 14)
• CBRNE Logistical Support Equipment (Category 19)
• Other Authorized Equipment (Category 21)
In addition to the above, general-purpose vehicles may be procured in order to carry out the responsibilities
of the EMPG Program.
If recipients have questions concerning the eligibility of equipment not specifically addressed in the AEL,
they should contact their Regional EMPG Program Manager for clarification. Applicants should analyze the
cost benefits of purchasing versus leasing equipment, especially high-cost items and those subject to rapid
technical advances. Large equipment purchases must be identified and explained. For more information
regarding property management standards for equipment, please reference 2 C.F.R. Part 200, including 2
C.F.R. §§ 200.310, 200.313, and 200.316. Also see 2 C.F.R. §§ 200.216, 200.471, and FEMA Policy #405-
143-1, or successor policy, regarding prohibitions on covered telecommunications equipment or services.
Recipients using EMPG Program funds to support emergency communications equipment activities must
comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on
technical standards that ensure and enhance interoperable communications. This SAFECOM Guidance can
be found at CISA Funding Resources.
In general, with exception of critical emergency supplies and the associated inventory management plan,
equipment included in the AEL may be purchased without separate approval from FEMA. However, as
with all grant-funded activities, the equipment purchase must be well justified and reasonable. Furthermore,
the purchase must be supported by the approved Work Plan. If the equipment is not clearly supported by the
approved Work Plan, the recipient must seek advance approval from the applicable FEMA Regional Grant
Program Office prior to purchasing the equipment, and an updated Work Plan may be required.
FEMA will consider requests to purchase equipment that is not listed in the AEL on a case-by-case basis.
Such requests should be submitted in writing to the applicable FEMA Regional Grant Program Office.
FEMA’s review and approval of such requests will involve both the FEMA regional office and headquarters
program staff to ensure nationwide consistency in the decision-making process and to support any
necessary updates to the AEL.
Requirements for Small Unmanned Aircraft Systems
All requests to purchase Small Unmanned Aircraft System (sUAS) must comply with IB 426 and must
include the policies and procedures in place to safeguard individuals’ privacy, civil rights, and civil liberties
in the jurisdiction that will purchase, take title to, or otherwise use the sUAS equipment. Additional
information and requirements applicable to sUAS purchases can be found in the AEL at 03OE-07-SUAS.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA alerted of an advisory guidance document issued by DHS, the Department of
Justice, the Federal Aviation Administration, and the Federal Communications Commission: Advisory on
the Application of Federal Laws to the Acquisition and USe of Technology to Detect and Mitigate UAS.
The purpose of the advisory guidance document is to help non-federal public and private entities better
understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate
threats posed by UAS operations (i.e., Counter-UAS or C-UAS). The Departments and Agencies issuing the
advisory guidance document, and FEMA, do not have the authority to approve non-federal public or private
use of UAS detection or mitigation capabilities, nor do they conduct legal reviews of commercially
EMPG Program Appendix | May 2022 Page H-22
available product compliance with those laws. The advisory does not address state and local laws nor
potential civil liability, which UAS detection and mitigation capabilities may also implicate. It is strongly
recommended that, prior to the testing, acquisition, installation, or use of UAS detection and/or mitigation
systems, entities seek the advice of counsel experienced with both federal and state criminal, surveillance,
and communications laws. Entities should conduct their own legal and technical analysis of each UAS
detection and/or mitigation system and should not rely solely on vendors’ representations of the systems’
legality or functionality. Please also see the DHS press release on this topic for further information:
Interagency Issues Advisory on Use of Technology to Detect and Mitigate UAS.
Funding for Critical Emergency Supplies
Critical emergency supplies—such as shelf stable products, water, and basic medical supplies—are an
allowable expense under the EMPG Program. FEMA must approve a state’s five-year viable inventory
management plan prior to allocating grant funds for stockpiling purposes. The five-year plan should include
a distribution strategy and related sustainment costs if the grant expenditure is over $100,000.
Training
EMPG Program funds may be used for a range of emergency management-related training activities to
enhance the capabilities of state and local emergency management personnel through the establishment,
support, conduct, and attendance of training. Training activities should align to a current, multi-year IPP
developed through an annual IPPW and build from training gaps identified in the THIRA/SPR process.
Further guidance concerning the IPP and the IPPW can be found at Preparedness Toolkit Program
Management Templates. Training should:
• Foster the development of a community-oriented approach to emergency management that
emphasizes engagement at the community level;
• Strengthen best practices; and
• Provide a path toward building sustainable resilience.
Allowable training-related costs include the following:
• Funds Used to Develop, Deliver, and Evaluate Training: Includes costs related to administering
training, such as planning, scheduling, facilities, materials and supplies, reproduction of materials,
and equipment. Training should provide the opportunity to demonstrate and validate skills learned,
as well as to identify any gaps in these skills. Any training or training gaps, including those for
children and individuals with disabilities or other access and functional needs, should be identified
in the multi-year IPP and addressed in the training cycle. States are encouraged to use existing
training rather than developing new courses. When developing new courses, states are encouraged
to apply the Analyze, Design, Develop, Implement, and Evaluate (ADDIE) model for instruction
design. More information is available at First Responder Training and Education Division.
• Overtime and Backfill: Overtime costs, including payments related to backfilling personnel, that
are the direct result of attendance at FEMA and/or approved training courses and programs are
allowable. These costs are allowed only to the extent the payment for such services is in accordance
with the policies of the state or unit(s) of local government and has the approval of the state or
FEMA, whichever is applicable. In no case is dual compensation allowable. That is, an employee of
a unit of government may not receive compensation from their unit or agency of government and
from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may
benefit both activities.
• Travel: Travel costs (e.g., airfare, mileage, per diem, and hotel) are allowable as expenses by
employees who are on travel status for official business related to approved training. International
travel is not an allowable cost under this program unless approved in advance by FEMA.
EMPG Program Appendix | May 2022 Page H-23
• Hiring of Full- or Part-Time Staff or Contractors/Consultants: Full- or part-time staff or
contractors/consultants may be hired to support direct training-related activities. Hiring of
contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§
200.317-200.327. Payment of salaries and fringe benefits must be in accordance with the policies of
the state or unit(s) of local government and have the approval of the state or FEMA, whichever is
applicable.
• Certification/Recertification of Instructors: Costs associated with the certification and re-
certification of instructors are allowed. States are encouraged to follow the FEMA Instructor
Quality Assurance Program to ensure a minimum level of competency and corresponding levels of
evaluation of student learning. This is particularly important for those courses that involve training
of trainers.
Additional types of allowable training or training-related activities include, but are not limited to:
• Developing/enhancing systems to monitor training programs
• Conducting all-hazards emergency management training
• Attending EMI training or delivering EMI train-the-trainer courses
• Attending other FEMA-approved emergency management training
• State-approved, locally sponsored CERT training
• Mass evacuation training at local, state, territorial and tribal levels
Exercises
Allowable exercise-related costs include:
• Funds Used to Design, Develop, Conduct and Evaluate Preparedness Exercises: This includes
costs related to planning, meeting space and other meeting costs, facilitation costs, materials and
supplies, travel, and documentation. Recipients are encouraged to use free public
space/locations/facilities whenever available prior to the rental of space/locations/facilities.
Exercises should provide the opportunity to demonstrate and validate skills learned, as well as to
identify any gaps in these skills. Gaps identified during an exercise, including those for children and
individuals with disabilities or other access and functional needs, should be included in the AAR/IP
and addressed in the exercise cycle.
• Hiring of Full- or Part-Time Staff or Contractors/Consultants: Full- or part-time staff may be
hired to support direct exercise activities. Payment of salaries and fringe benefits must be in
accordance with the policies of the state or unit(s) of local government and have the approval of the
state or FEMA, whichever is applicable. The services of contractors/consultants may also be
procured to support the design, development, conduct, and evaluation of exercises. Hiring of
contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§
200.317-200.327.
• Overtime and Backfill: The entire amount of overtime costs, including payments related to
backfilling personnel, that are the direct result of time spent on the design, development and
conduct of exercises are allowable expenses. These costs are allowed only to the extent the payment
for such services is in accordance with the policies of the state or unit(s) of local government and
has the approval of the state or FEMA, whichever is applicable. Dual compensation is never
allowable, meaning, in other words, that an employee of a unit of government may not receive
compensation from their unit or agency of government and from an award for a single period of
time (e.g., 1:00 p.m. to 5:00 p.m.), even though their work may benefit both entities.
• Travel: Travel costs (e.g., airfare, mileage, per diem, hotel) are allowable as expenses by
employees who are on travel status for official business related to the planning and conduct of the
exercise activities.
EMPG Program Appendix | May 2022 Page H-24
• Supplies: Supplies are items that are expended or consumed while planning and conducting the
exercise activities (e.g., gloves, non-sterile masks, and disposable protective equipment).
• HSEEP Implementation: This refers to costs related to developing and maintaining an exercise
program consistent with HSEEP.
• Other Items: These costs are limited to items consumed in direct support of exercise activities,
such as space/locations rentals for planning and conducting an exercise, equipment rentals (e.g.,
portable toilets, tents), food/refreshments, and the procurement of other essential nondurable goods.
Costs associated with inclusive practices and the provision of reasonable accommodations and
modifications that facilitate full access for children and adults with disabilities are allowable.
Unauthorized exercise-related costs include:
• Reimbursement for maintenance and/or wear and tear costs of general use vehicles (e.g.,
construction vehicles) and emergency response apparatus (e.g., fire trucks, ambulances). The only
vehicle costs that are reimbursable are fuel/gasoline or mileage.
• Equipment that is purchased for permanent installation and/or use beyond the scope of exercise
conduct (e.g., electronic messaging signs)
• Durable and nondurable goods purchased for installation and/or use beyond the scope of exercise
conduct
Construction and Renovation
Construction and renovation projects for a state, local, tribal, or territorial government’s principal
Emergency Operations Center (EOC), as defined by the SAA are allowable under the EMPG Program.
FEMA must provide written approval prior to the use of any EMPG Program funds for construction or
renovation. Requests for EMPG Program funds for construction of an EOC must be accompanied by an
EOC Investment Justification (located in the Related Documents tab of the EMPG Program Grants.gov
posting) to their Regional EMPG Program Manager for review. Additionally, recipients are required to
submit a SF-424C Form, SF-424D Form, and Budget detail citing the project costs.
The above examples are not intended to exclude other construction projects as potentially allowable costs.
For example, construction of a facility for the storage and distribution of critical emergency supplies and/or
to serve as a staging area for deployment of emergency response resources is potentially an allowable
expense. Other construction or renovation projects, such as a secondary or local EOC, will be considered on
a case-by-case basis, as described below in the guidance regarding advance written approval.
Advance Approval Requirement
Recipients must receive advance written approval from FEMA prior to the use of any annual EMPG
Program funds for construction or renovation, including such activities at the subrecipient level. Such costs
would need to fall within the scope of the recipient’s final approved Work Plan, otherwise an updated Work
Plan may be required. Such requests should be submitted in writing to the applicable FEMA Regional Grant
Program Office. FEMA’s review and approval will involve both the regional office and the FEMA Grant
Programs Directorate.
Real Property Use and Disposition Requirements
Real property improved under a federal award falls under the 2 C.F.R. Part 200 guidance for real property.
In accordance with 2 C.F.R. § 200.311, a recipient or subrecipient may only use real property acquired or
improved under a federal award for the originally authorized purpose, as long as it is needed for that
purpose, during which time the recipient or subrecipient must not dispose of or encumber its title or other
interests. However, upon the end of that period where it needs the property for the originally authorized
purpose (i.e., the functional use of the property for which FEMA awarded the grant), the recipient or
EMPG Program Appendix | May 2022 Page H-25
subrecipient will then dispose of the property in keeping with the requirements set forth in 2 C.F.R. §
200.311.
When a grant-funded property is no longer needed for the originally authorized purpose, the recipient or
subrecipient (through the pass-through entity) must obtain disposition instructions from the cognizant
FEMA Regional Administrator or the pass-through entity. For additional information on this, see
Information Bulletin 458a, Clarifying Guidance for the Annual Emergency Management Performance
Grant (EMPG) and the FY 2020 COVID-19 EMPG Supplemental (EMPG-S) Programs.
Construction of Communication Towers
When applying for funds to construct communication towers, recipients and subrecipients must submit
evidence that the Federal Communication Commission’s Section 106 review process has been completed
and submit all documentation resulting from that review to FEMA prior to submitting materials for EHP
review. Recipients and subrecipients are also encouraged to have completed as many steps as possible for a
successful EHP review in support of their proposal for funding (e.g., coordination with their State Historic
Preservation Office to identify potential historic preservation issues and to discuss the potential for project
effects, compliance with all state and EHP laws and requirements). Projects for which the recipient believes
an Environmental Assessment may be needed, as defined in DHS Instruction Manual 023-01-001-01, Rev
01, FEMA Directive 108-1 and FEMA Instruction 108-1-1, must also be identified to the Regional EMPG
Program Manager within six months of the award, and completed EHP review materials must be submitted
no later than 12 months before the end of the period of performance. EHP review packets should be sent to
gpdehpinfo@fema.gov.
Davis-Bacon Act Compliance
EMPG Program recipients using funds for construction projects must comply with the Davis-Bacon Act and
subsequent legislation (40 U.S.C. §§ 3141 et seq.). Grant recipients must ensure that their contractors or
subcontractors for construction projects pay workers no less than the prevailing wages for laborers and
mechanics employed on projects of a character similar to the contract work in the civil subdivision of the
state in which the work is to be performed. Additional information regarding compliance with the Davis-
Bacon Act, including Department of Labor wage determinations, is available at Davis-Bacon and Related
Acts.
Accessibility Compliance
EMPG Program recipients using funds to build or alter buildings must comply with accessibility
requirements under the Rehabilitation Act of 1973 and Architectural Barriers Act of 1968 (ABA), as well as
the Americans with Disabilities Act (ADA), if applicable, to ensure individuals with disabilities have access
to such buildings. Accessibility standards under the ABA and ADA are highly similar. Additional
information regarding compliance with the Architectural Barriers Act is available at Guide to the ABA.
Acquisition of Real Property
Acquisition of real property is permissible if such property is needed to support other allowable program
costs or activities. For additional information on this, see Information Bulletin 458a, Clarifying Guidance
for the Annual Emergency Management Performance Grant (EMPG) and the FY 2020 COVID-19 EMPG
Supplemental (EMPG-S) Programs.
Advance Approval Requirement
Consistent with the requirements outlined above regarding construction activities, recipients and
subrecipients (through the pass-through entity) must obtain advance written approval from the cognizant
FEMA Regional Administrator prior to obligating annual EMPG Program funds for acquisition of real
property. Additionally, in cases of acquisition or improving real property, recipients are required to submit a
EMPG Program Appendix | May 2022 Page H-26
SF-429-B, Real Property Status Report, Attachment B providing details of the relevant property to be
acquired.
Property Use, Reporting, and Disposition Requirements
The acquisition, use, and disposition of real property shall be subject to the provisions of 2 C.F.R. Part 200.
In accordance with 2 C.F.R. Part 200, recipients and subrecipients are required to report on the status of the
acquired property on an annual basis using SF-429-A Real Property Status Report, Attachment A (General
Reporting). Such reporting shall continue as long as the property is being used for the originally authorized
purpose.
The same use and disposition guidance as outlined in Sections III.D.3 above applies to real property
acquired with annual EMPG Program funds. For additional information on this, see Information Bulletin
458a, Clarifying Guidance for the Annual Emergency Management Performance Grant (EMPG) and the FY
2020 COVID-19 EMPG Supplemental (EMPG-S) Programs.
Leasing of Real Property
Leasing of real property is permissible if the property is needed to support other allowable annual EMPG
Program activities.
Advance Approval Requirement
Recipients and subrecipients (through the pass-through entity) must obtain advance written approval from
the cognizant FEMA Regional Administrator prior to obligating annual EMPG Program funds for the
leasing of real property.
Allowable Period of Lease Expenses
In cases where a property will be leased and the lease will be paid in full or in part using annual EMPG
Program, any costs associated with the lease that are charged to an annual EMPG Program award must
occur within the period of performance of the associated award(s). Real property lease costs must also
comply with 2 C.F.R. Part 200.
Maintenance and Sustainment
Use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement costs,
upgrades, and user fees are allowable under all active grant awards, unless otherwise noted.
EMPG Program funds are intended to support the Goal and fund activities and projects that build and
sustain the capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover
from those threats and hazards that pose the greatest risk to the security of the Nation. To assist recipients in
meeting this objective, the policy set forth in IB 379: Guidance to State Administrative Agencies to
Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for the expansion of eligible
maintenance and sustainment costs, which must be:
1) In direct support of existing capabilities;
2) An otherwise allowable expenditure under the applicable grant program;
3) Tied to one of the core capabilities in the five mission areas contained within the Goal, and;
4) Shareable through the EMAC.
Additionally, eligible costs may also be in support of equipment, training, and critical resources that have
previously been purchased with either federal grant funding or any other source of funding other than
FEMA preparedness grant program dollars.
EMPG Program Appendix | May 2022 Page H-27
Unallowable Costs
Grant funds may not be used for the following:
• Unallowable Equipment: Grant funds must comply with IB 426 and may not be used for the
purchase of firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft, vessels, or
vehicles of any kind with weapons installed
• Expenditures for weapons systems and ammunition
• Costs associated with hiring, equipping, training, etc. sworn public safety officers whose primary
job responsibilities include fulfilling traditional public safety duties such as law enforcement,
firefighting, emergency medical services, or other first responder duties
• Costs that supplant traditional public safety positions and responsibilities
• Activities and projects unrelated to the completion and implementation of the EMPG Program
Recipients should consult with their Regional EMPG Program Manager prior to making any investment that
does not clearly meet the allowable expense criteria established in this Manual and the EMPG Program
NOFO.
EMPG Program Appendix | May 2022 Page H-28
EMPG Program Work Plan
Submission of an EMPG Program Work Plan is mandatory. It is a required component of the EMPG
Program application. The Work Plan outlines the state’s emergency management sustainment and
enhancement efforts, including new and ongoing activities and projects, that are driven by identified
preparedness priorities and proposed for the EMPG Program period of performance. An FY 2022 EMPG
Program Work Plan Template (available on the Grants.gov EMPG Program application page and on the
FEMA.gov website at EMPG) is provided to facilitate the work plan development process. The submitted
Work Plan must address all the data and information requirements included in the FY 2022 EMPG
Program Work Plan Template and in the supplemental guidance included in this section. Therefore,
EMPG Program applicants are strongly encouraged to use the provided FY 2022 EMPG Program Work
Plan Template.
Prior to submission of the EMPG Program Work Plan, the applicant must work with the Regional
Administrator or designated Regional EMPG Program Manager to identify three to five priority areas
which will serve as the focus for EMPG Program-funded investments. The priorities must be mutually
agreed to by the applicant and Regional Administrator and should be driven by the THIRA/SPR process –
specifically, the outputs from the THIRA/SPR process – and other relevant information sources such as
AARs, audit and monitoring findings, Hazard Mitigation Plans and other deliberate planning products.
Priorities should also reflect those included in each recipient's IPP so that recipients are focusing all
investments, projects, and other resources on a common set of priorities. As they select priorities,
applicants should consider which capability gaps would be most operationally consequential, must be
closed most urgently, and could be meaningfully addressed within the period of performance. Applicants
should refer to the EMPG Program NOFO for further guidance on the priority identification process.
Applicants must set at least one performance goal for each RA agreed-upon priority area that achieves a
specific outcome. Each goal must be specific, measurable, and achievable within the period of
performance, relevant to the priority area, and have a target date for completion. Applicants must describe
how achieving each goal or objective will impact the priority area it supports by the end of the period of
performance. Each goal must include an estimate quantifying the extent to which the supporting
investments will close capability gaps (e.g., “Increase the percentage of people who can find and secure
long-term housing by 10% within 1 year of an incident”). The FY 2022 EMPG Program Work Plan
Template includes instructions and examples to help guide this process so that recipients can develop
goals that focus on achieving specific outcomes.
The Regional Administrator or designated Regional EMPG Program Manager will ensure that the
mutually agreed priorities are fully addressed in the EMPG Program Work Plan. In addition, the EMPG
Program Regional Administrator must approve final Work Plans before states may draw down EMPG
Program funds. Grant funds will be released upon approval of the state’s final Work Plan.
Following Work Plan approval, regional EMPG Program Managers will work closely with recipients to
monitor progress toward goals and activities in the Work Plans during the performance period and may
request further documentation from the recipients to clarify the projected Work Plan. Further, in
accordance with 2 C.F.R. §200.308 – Revision of budget and program plans, any changes to the approved
Work Plan – including changes in project scope and budget changes within any direct cost category
exceeding 10 percent of the total award amount – will require advance approval from the Regional
Administrator or designated Regional EMPG Program Manager.
EMPG Program Appendix | May 2022 Page H-29
EMPG Program Work Plan Instructions
The FY 2022 EMPG Program Work Plan Template has been updated to support the collection of
objective information and quantitative data that will allow FEMA to measure program effectiveness and
investment impacts more effectively. This also enables compliance with 2 C.F.R. § 200.301, which
requires federal awarding agencies to measure recipient performance to show achievement of program
goals and objectives, share lessons learned, improve program outcomes, and foster adoption of promising
practices. To this end, the FY 2022 EMPG Program guidance in the NOFO and Work Plan requires
recipients to link EMPG Program-funded investments to THIRA/SPR results and other relevant materials
that inform capability priorities and needs and to include specific performance measures that will allow
FEMA to measure the impact of those investments based on the core capabilities that are addressed.
The FY 2022 EMPG Program Work Plan Template largely complements the THIRA/SPR process
outlined in the Comprehensive Preparedness Guide (CPG) 201, Third Edition (CPG 201, v3). As noted in
CPG 201, v3, a coordinated approach to track investments, and understand the return on investments, can
help improve the effectiveness of those investments. Tracking how EMPG Program-funded investments
result in specific, quantitative changes in capabilities can help guide communities’ strategic planning
considerations and inform resource allocation decisions that will maximize effectiveness in building or
sustaining capabilities. Therefore, applicants are encouraged to refer to CPG 201, v3, along with their
most recent THIRA and SPR, when developing their EMPG Program Work Plan.
The FY 2022 EMPG Program Work Plan Template consists of the following tabs: Definitions and
Guidance, Quick Links, Grant Investment Strategy, Grant Activities Outline, Detailed Budget –
Excluding M&A, Budget Narrative – Excluding M&A, Detailed Budget – M&A Only, Budget Narrative
– M&A Only, EMPG Program Summary, Implementation Schedule, Training Data Table, and Exercise
Data Table. As explained above, the focus of the FY 2022 EMPG Program Work Plan Template is on
improving data collection to better enable measurement of grant outcomes. Therefore, the narrative
content is minimized and many of the cells include dropdowns for selecting applicable data. This
approach also helps to simplify the Work Plan development process.
Instructions for each Work Plan section are provided below. Additional guidance and instructions are
provided in the FY 2022 EMPG Program Work Plan Template.
Definitions and Guidance
The Definitions and Guidance tab collects applicant information and provides instructions for completing
each subsequent tab.
Quick Links
The Quick Links Tab uses the link functionality in Excel to allow users to navigate throughout the
template quickly and minimize the need to scroll through projects and implementation schedules.
Grant Investment Strategy
The intent of the Grant Investment Strategy tab of the FY 2022 EMPG Program Work Plan Template is to
provide an overview of the state/territory's preparedness investment strategy. It should serve as the
foundation for completing the remainder of the Work Plan. It includes separate sections to explain the
following:
• The performance goals associated with each priority area
• The most recent THIRA/SPR results
EMPG Program Appendix | May 2022 Page H-30
• Significant risks and capability gaps that currently exist
• Resulting preparedness priorities
• The anticipated impact of the proposed EMPG Program-funded investments
For the Performance Goals section, the applicant should identify the three to five priorities that were
mutually agreed to and approved between the Regional Administrator and the state/territory. These goals
serve as the focus for the EMPG Program-funded investments. The reference materials used to identify
the priorities should be cited and their relevance explained in this section.
At least one performance goal should be identified for each priority area. Each goal must be specific,
measurable, achievable within the period of performance, relevant to the priority area, and have a target
date for completion (i.e., SMART goal). It should describe how achieving each goal will impact the
priority area it supports by the end of the period of performance.
Grant Activities Outline
The Grant Activities Outline is used to capture the proposed EMPG Program-funded projects and link
them to the identified priorities, performance goals, and gaps or needs. Coupled with the Implementation
Schedule, the Grant Activities Outline supports identification and tracking of EMPG Program-funded
project outcomes, which will enable better understanding of the impacts of those investments relative to
the performance goals and the associated core capabilities. Applicants can also designate whether a
project addresses equity considerations and/or climate change impacts. Examples of allowable activities
and associated core capabilities for projects that address the FY 2022 EMPG Program national priorities
of equity, climate resilience, and readiness can be found in the FY 2022 EMPG Program NOFO.
The Grant Activities Outline includes sections that allow the applicant to identify the performance goals
that are supported by each project and the milestones that are critical to accomplishing each goal.
Additional guidance on performance goals and milestones, including specific examples of each, are
provided below.
The Grant Activities Outline also requires the applicant to explain the objective and anticipated impact of
each project relative to the associated priorities, performance goals, and related core capabilities:
• The “Project Objective” should explain what the project will accomplish; specifically, how the
project will address the identified gap or need and how it supports one or more of the identified
performance goals.
• The “Anticipated Project Impact” should explain the expected project outcome relative to the
associated priorities and performance goals.
o The impact statement should include a quantitative estimate of the degree to which the
project will contribute to achieving the identified performance goal (see hierarchy
example below).
Effective completion of the Grant Activities Outline requires an understanding of the established planning
hierarchy. Priorities are at the top of the hierarchy, followed by performance goals that define a clear
outcome or end-state and provide the basis for addressing each priority. Project proposals should be
identified based on the performance goals. High priority capability gaps or needs identified through the
THIRA/SPR process, particularly SPR Step 2, and other assessments are also used to inform project
selection and to identify specific project objectives. Project objectives, and accompanying impact
statements, should complement the performance goals by including similar outcome-focused metrics, as
explained above. Lastly, identifying the specific project activities are the last step in the process of
completing the GAO. Project activities are key components and/or milestones that are critical to
successful completion of the project.
EMPG Program Appendix | May 2022 Page H-31
An example of this planning hierarchy for completing the GAO is provided below:
Priority: Logistics and Supply Chain Management
Performance Goal: Within 24 hours of an incident, identify and mobilize life-sustaining
commodities, resources, and services to 10,000 people requiring shelter and 100,000 people
requiring food and water. Maintain distribution system for at least 30 days.
• Project: Update State Logistics and Distribution Management Plan and qualify 40
additional personnel for logistics operations in NQS.
o Project Objective/Impact: Increase capacity to identify and mobilize life-sustaining
commodities, resources, and services to people requiring shelter, food, and water by
50%, allowing the state to do so for 7,500 people requiring shelter and 75,000
requiring food and water within 24 hours of an incident and maintain that distribution
system for at least 30 days.
• Activity: Convene cross-discipline working group meeting on May 30, 2022, to
review current State Logistics and Distribution Management Plan
All EMPG Program-funded investments must be accounted for in the Grant Activities Outline. However,
recognizing that some sustainment activities, such as funding of emergency manager salaries, may not
align to a specific priority or performance goal, applicants are not required to identify priorities and
performance goals for such investments. However, all other portions of the Grant Activities Outline must
be completed as a means to justify the applicable sustainment costs.
In cases where emergency management personnel are not assigned to support specific projects included in
the Work Plan, the applicant may choose to create a single project (e.g., Emergency Management
Personnel Project) to encompass the majority of the EMPG Program-funded salaries and fringe benefits
costs. This single project would be populated on the Grant Activities Outline and include the associated
activities, priorities, goals, anticipated outcomes, milestones, etc. for the applicable EMPG Program-
funded emergency management staff, including staff supporting the M&A activities.
The various elements of the Grant Activities Outline tab are outlined below, along with basic instructions
for completing the required entries. Supplemental guidance and instructions are included in the FY 2022
EMPG Program Work Plan Template.
• Project Name: Provide a descriptive name for each planned project. Examples include
“Development of Emergency Function Annexes,” “Development of Earthquake Scenario Loss
Estimations,” “Implementation of Statewide Interoperability Plan,” “NIMS Training for
Emergency Management Personnel,” “Development of Emergency Preparedness Plan for
Individuals with Disabilities,” etc.
• Brief Project Description: Provide further details on the project, particularly where the project
name does not sufficiently describe the project.
• Gap or Need Addressed: Briefly describe the specific gap or need addressed by the project.
• Reference for Identified Gap or Need: Select the documentation used to identify the cited gap
or need from the drop-down menu.
• Project Objective: Explain how the project addresses the identified gap or need, and how it
supports the identified priorities and performance goals.
• Anticipated Project Impact: Explain the expected project outcome relative to the associated
priorities and performance goals.
• Build or Sustain: Select whether the project will build or maintain/sustain the identified core
capability(ies).
• Equity: Select whether the project will address equity considerations.
EMPG Program Appendix | May 2022 Page H-32
• Climate Change: Select whether the project will address the impacts of climate change.
• EMPG Program National Priority Area: Select the applicable National Priority Area from the
drop-down menu.
• Regional Administrator (RA) Agreed Upon Priority Area: Select from a drop-down list of
the 32 core capabilities and other priorities identified in the latest version of the National
Preparedness Report. If the priority is not included in the drop-down list, enter “other” for
Primary, Secondary and/or Tertiary, and then enter the priority in the adjacent cell.
• POETE Category: Select whether the project relates to Planning, Organization, Equipment,
Training, or Exercises. Multiple POETE categories can be selected to accommodate projects that
span multiple categories. For example, building capability often involves a combination of
planning, training, and exercise activities. Space is provided to populate the Primary, Secondary
and Tertiary POETE category.
• Emergency Management Accreditation Program (EMAP) Standard Element: This field is
optional. It is made available to those states/territories that are EMAP certified and want to
continue tracking their investments by EMAP Standard Elements. Select the appropriate EMAP
Standard Elements from the drop-down menu, if applicable.
• Mission Area: Select the appropriate preparedness mission area supported by the project:
Prevention, Protection, Mitigation, Response, or Recovery. Multiple mission areas can be
selected to accommodate projects such as plans and exercises that involve multiple mission
areas, and space is provided to populate the Primary, Secondary and Tertiary Mission Areas.
• Core Capabilities: Select up to five core capabilities supported by the project. Indicate whether
the Core Capability has a target with a gap rated as high priority.
• Performance Goals: Select the performance goal(s) from the drop-down menu. The drop-
down menu will consist of the performance goals as entered in the Grant Investment Strategy.
• Current Capability Metrics: Identify capability metrics prior to the project implementation.
• Milestones: Identify key project activities and other deliverables or outputs that are critical to
accomplishing the identified performance goal and can be tracked to demonstrate progress
toward achieving the performance goal.
Detailed Budget – Excluding M&A
The Detailed Budget – Excluding M&A tab enables a full accounting of all project activity costs,
excluding M&A costs. This tab contains an itemization of non-M&A costs related to personnel, fringe
benefits, travel, equipment, supplies, contractual services, construction, other, and indirect costs. For
personnel and fringe benefits, the position title and percentage of time or fringe allocated to the EMPG
Program grant is required. Each line item is assigned to its relevant project, allowing the information in
mission areas, core capabilities, priorities, EMAP, and POETE categories to populate accordingly. This
enables a breakdown of the full EMPG Program budget into various categories: Mission Area, Core
Capabilities, National Priority Area, RA Agreed Upon Priority, EMAP Standard Elements, and POETE
Category. The cells for each of these categories are automatically populated based on the project number
as identified in the Grant Activities Outline.
Budget Narrative – Excluding M&A
The purpose of the Budget Narrative – Excluding M&A tab is to 1) justify the need for each line item and
the cost estimates; 2) explain how costs relate to the programmatic goals of the project(s); and 3)
supplement other budget information provided on the Detailed Budget – Excluding M&A tab. This tab
will include a narrative for each cost category of the budget. For the Cost Share, applicants must
include a detailed description of the source of the match/cost share. If funds or services are to be
provided by a third party for in-kind match, a dated letter of commitment is required to document the
donation. If the M&A Detailed Budget tab includes Indirect Costs, an approved Indirect Cost Rate
EMPG Program Appendix | May 2022 Page H-33
Agreement signed by the recipient agency and the cognizant agency for the recipient, or a copy of the
proposal to the cognizant federal or state agency for an indirect cost rate, must be included in the
submission of the Work Plan for application purposes. Applicants who do not have a current negotiated
indirect cost rate agreement (including a provisional rate) and wish to charge the de minimis rate must
reach out to the Grants Management Specialist for further instructions. Applicants who wish to use a cost
allocation plan in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for
further instructions.
Detailed Budget – M&A Only
This Detailed Budget – M&A Only tab enables a full accounting of all project activity costs as they relate
specifically to M&A costs. This tab contains an itemization of only M&A costs related to personnel,
fringe benefits, travel, equipment, supplies, contractual services, construction, and other direct costs. For
personnel and fringe benefits, the position title and percentage of time or fringe allocated to the
EMPG Program grant is required. Each line item is assigned to its relevant project, allowing the
information in mission areas, core capabilities, priorities, EMAP, and POETE categories to populate
accordingly. This enables a breakdown of the full EMPG Program budget into various categories,
including the following: Mission Area, Core Capabilities, National Priority Area, RA Agreed Upon
Priority, EMAP Standard Elements, and POETE Category. The cells for each of these categories are
automatically populated based on the project number as identified in the Grant Activities Outline.
Budget Narrative – M&A Only
The purpose of the Budget Narrative – M&A Only tab is to: 1) justify the need for each line item and the
cost estimates; 2) explain how costs relate to the programmatic goals of the project(s); and 3) supplement
other budget information provided on the Detailed Budget– M&A Only tab. For the Cost Share,
applicants must include a detailed description of the source of the cost share/matching funds. If funds or
services are to be provided by a third party for in-kind match, a dated letter of commitment is required to
document the donation. This tab will include a narrative for each cost category of the budget.
Information for the Detailed Budget and Budget Narrative
This section of the Work Plan is a detailed description of the budget found in the SF-424A and must
include a detailed discussion of how EMPG Program funds will be used. Applicants must itemize costs
related to personnel, fringe benefits, travel, equipment, supplies, contractual costs, other direct costs,
indirect costs, and total costs.
Applicants should use the following instructions and budget cost category descriptions to complete the
Budget Detail section of the Work Plan.
Personnel: List each position with a brief description of the duties and responsibilities (no personnel
names), as well as the salary computation for staff. If a Cost-of-Living Adjustment increase and/or merit
pay increase in salary will be provided for the position, include those costs in calculations for personnel
and the associated fringe benefits on the applicable Detailed Budget and the Budget Narrative.
Fringe Benefits: List the computation for fringe benefits for each of the personnel listed in the budget
worksheet. Estimated rates for fringe are allowable but provide the basis for that estimation in the budget
narrative (e.g., average percent fringe paid for most employees within the agency). If not using an
estimate, list fringe benefit and the associated costs for each employee that will be paid by EMPG
Program funding (e.g., Social Security/FICA, Unemployment Compensation, Medicare, Retirement,
Health Insurance, Life Insurance, etc.). Also, in cases where fringe benefits costs are included in an
indirect cost rate agreement, the fringe benefits cannot also be charged as a direct cost for
reimbursement.
EMPG Program Appendix | May 2022 Page H-34
Travel: Specify the mileage, per diem, estimated number of trips in-state and out-of-state, number of
travelers, and other costs for each type of travel for staff. Travel may be integral to the purpose of the
proposed project (e.g., management, monitoring and/or oversight of grant award and/or subrecipients) or
related to propose project activities (e.g., attendance at training or meetings related to management of the
EMPG Program award). Travel costs identified in this section are for employees of the
applicant/recipient only. For travel costs related to staff training, include as many details as possible
about each proposed training cost, including the name of the training course(s), training provider,
personnel who will attend the training, proposed dates (estimates are accepted), etc. Travel category
costs do not include 1) costs for travel of consultants, contractors, consortia members, or other partner
organizations, which are included in the “Contractual” category; or 2) travel costs for employees of
subrecipient agencies (those should be included in the Contractual category, if applicable).
Equipment: List each equipment item for EMPG Program purposes only by Line Item Name and in the
same order as listed on the Detailed Budget. Include a brief description of each equipment item (no
brand names); per unit cost, quantity and total cost; location of equipment (if other than the direct
recipient agency); and how the equipment will be utilized. Equipment is defined in 2 C.F.R. § 200.1.
Supplies: Include all tangible personal property other than those described in the definition of
“equipment” as defined by 2 C.F.R. § 200.1. Supplies are also defined in 2 C.F.R. § 200.1. The budget
detail should identify categories of supplies to be procured for EMPG Program purposes only (e.g.,
printing supplies, office supplies, etc.) and the calculation of those costs (e.g., based on monthly rates or
based on an average of previous years’ similar costs). Non-tangible goods and services associated with
supplies, such as printing service, photocopy services, and rental costs should be included in the “Other”
category. Provide the basis for calculation of supplies including the Line Item Name and list supplies in
the Budget Narrative in the same order as listed on the Detailed Budget. Subrecipient M&A and non-
M&A costs should be included in the “Other” category.
Contractual: Identify each proposed contract related to EMPG Program purposes only and specify its
purpose and estimated cost. Contractual/consultant services are those services to be carried out by an
individual or organization (do not include company or individual names in budget narrative), other than
the applicant, in the form of a procurement relationship. Leased or rented goods (equipment or supplies)
for EMPG Program purposes should be included in the “Other” category. The applicant should list the
proposed contract activities along with a brief description of the scope of EMPG Program work or
services to be provided and proposed duration. Include the basis for the calculation of contractual
services costs (e.g., contractor training instructor speaking fee, contractor travel costs and contractor
instructional materials).
Other: This category should include only those types of direct costs that do not fit in any of the other
budget categories and are related to EMPG Program purposes only. Include a description of each cost by
Line-Item Name and in the same order as listed on the applicable Detailed Budget. Include the basis for
calculation of the costs. Examples of costs for EMPG Program purposes that may be in this category
include the following: insurance, rental/lease of equipment or supplies, equipment service or
maintenance contracts, printing or photocopying rental, etc. Subrecipient M&A and non-M&A costs
from their subawards (e.g., subgrants) are a distinct type of cost under this category. The term
“subaward” means an award of financial assistance (money or property) by any legal agreement made by
the recipient to an eligible subrecipient. This term does not include procurement purchases, technical
assistance in the form of services instead of money, or other assistance in the form of revenue sharing,
loans, loan guarantees, interest subsidies, insurance, or direct appropriations. Subcontracts are not
subawards and belong in the contractual category. Applicants must provide the aggregate amount they
propose to issue as subaward work and a description of the types of M&A and non-M&A activities to be
supported.
EMPG Program Appendix | May 2022 Page H-35
Construction: Include construction costs, including renovation projects for a state or territorial
government’s principal EOC. Include a description of the types of construction or renovation services
proposed and the calculation of these costs (no company or individual names). Subrecipient construction
costs should be included in the Other category. M&A funding cannot be used for construction or
renovation costs.
Indirect Costs: If indirect charges are budgeted, indicate the approved rate and base (the cost categories
for which this indirect cost percentage rate will be applied.) Indirect costs are those incurred by the
recipient for a common or joint purpose that benefit more than one cost objective or project, and are not
readily assignable to specific cost objectives or projects as a direct cost. In order for indirect costs to be
allowable, the applicant must have a federal or state negotiated indirect cost rate (e.g., fixed,
predetermined, final or provisional), or must have submitted a proposal to the cognizant federal or state
agency. An approved Indirect Cost Rate Agreement signed by the recipient agency and the cognizant
agency for the recipient, or a copy of the proposal to the cognizant federal or state agency for an indirect
cost rate, must be included in the submission of the Work Plan Template for application purposes.
Examples of Indirect Cost Rate calculations are shown below:
1. Personnel (Indirect Rate x Personnel = Indirect Costs)
2. Personnel and Fringe (Indirect Rate x Personnel & Fringe = Indirect Costs)
3. Total Direct Costs (Indirect Rate x Total Direct Costs = Indirect Costs)
Applicants who wish to use a cost allocation plan in lieu of an indirect cost rate must also reach out to
the FEMA Grants Management Specialist for further instructions. Per 2 C.F.R. Part 200, Appendix VII,
paragraph D.1.b, state and local governments are not permitted to use the de minimus rate without
seeking and receiving FEMA’s approval of a case-by-case exception. Applicants who wish to request the
case-by-case exception should reach out to their FEMA Grants Management Specialist for further
instructions.
Post-award requests to charge indirect costs will be considered on a case-by-case basis and based upon
the submission of an agreement or proposal as discussed above or based upon the de minimis rate or cost
allocation plan, as applicable.
EMPG Program Summary
This tab includes summary information for the award as entered in the budget tabs and the Grant Activity
Outline. The overall budget summary will include the total award amount, federal amount, non-federal
amount (cost share), and M&A amount, along with the calculated percentage of each. The additional
budget summary tables will calculate the amount allocated for federal funds, non-federal funds (cost
share) and total project costs for each cost category. There is also a budget summary table with similar
information for each primary mission area and core capability.
The EMPG Program Summary tab also provides users with an overview of their progress in the FY 2022
EMPG Program Performance Metrics. The metrics are automatically populated from the calculations of
information provided in the Grant Activities Outline. These metrics aim to provide the count, percentage,
and associated dollar amount affiliated with the following performance metrics: 1) Capability-building
Projects for Alignment to Capability Gaps in SPR; 2) Funding Spent on Capability-building Projects
Aligned to Capability Gaps in SPR; 3) Building Capabilities for High Priority Targets; 4) Regional and
National Priority Area Alignment; and 5) Plans-Training-Exercise Alignment. The EMPG Program
Summary Tab further provides a count of all projects that address equity considerations and climate
change impacts.
EMPG Program Appendix | May 2022 Page H-36
Implementation Schedule
The Implementation Schedule includes the basic elements of a project management plan. It is used to
capture key project activities to include both EMPG Program-funded activities that are critical to
accomplishing the project objectives as identified in the Grant Activities Outline, as well as tasks that
are essential to effective project management. Thus, this product can be used as a basic project
management tool to plan and track the progress of key project activities and associated tasks. Key
project activities should generally correlate with the “Milestones” identified for each project included in
the Grant Activities Outline.
The Implementation Schedule enables the applicant to identify key project activities by year/quarter, the
associated tasks, timelines, status reports, and challenges or risks that may affect successful completion
of the activity as planned. It also allows for the tracking of project progress by including estimated and
actual completion dates for each activity and the ability to enter quarterly accomplishments relating to
the activity. This functionality allows for quarterly reporting of project progress, in accordance with the
programmatic requirements of the EMPG Program. Also, data from the Implementation Schedule
should be completed and submitted to FEMA as a component of quarterly reporting on grant activities.
The Implementation Schedule further allows the applicant to explain how their project addresses equity
considerations. Possible examples include: 1) conducting vulnerability assessments to identify and fully
understand the vulnerabilities and needs of underserved communities relating to emergency
preparedness; and, 2) updating emergency operations plans to ensure the needs of underserved
communities are adequately addressed.
The Implementation Schedule also provides the applicant with the ability to explain how their project
addresses the impacts of climate change.
Training Data Table
To facilitate consistent data reporting and performance measures collection, the FY 2022 EMPG Program
Work Plan Template includes a Training Data Table. This table should reflect training activities outlined
in the multi-year IPP and completion of required EMPG Program training courses. The data requirements
are defined in the section below. Applicants/recipients are not required to report EMPG Program-funded
personnel costs associated with training. Training related to the NQS is not reported on the Training Data
Table. Also, data from the Training Data Table should be completed and submitted to FEMA as a
component of quarterly reporting on grant activities. Upon entering the project name or number in the
template, the cells located to the right of the main Training Data Table will auto-populate the associated
priority, mission area, capabilities, and functional areas based on the project data included in the Grant
Activities Outline.
Training Data Table Template
Project
Number
Project
Name
Name of
Training
Scheduled
Date
Date
Training
was
Conducted/
Completed
EMPG
Program
Required
Training?
(Y/N)
Number
of
Personnel
Trained
NIMS Training
Course Number
(if applicable)
Training
Identified
in IPP
(Y/N)
Training Data Table Definitions
• Column 1 – Project Number from the Grant Activities Outline
• Column 2 – Project Name from the Grant Activities Outline
EMPG Program Appendix | May 2022 Page H-37
• Column 3 – Name of training course
• Column 4 – Scheduled date of training course
• Column 5 – Date training was conducted or completed
• Column 6 – Is the training course required by the EMPG Program?
• Column 7 – Number of personnel trained
• Column 8 – NIMS Training Course Number (if applicable)
• Column 9 – Is the training identified in the multi-year IPP?
Exercise Data Table
To facilitate consistent data reporting and performance measure collection, an Exercise Data Table should
be completed for any exercises that meet EMPG Program requirements and/or exercises conducted in
whole or part with EMPG Program funds. The Exercise Data should include EMPG Program-funded
exercises and costs to run the exercise (e.g., planning, materials, props, contractual services for
conducting the exercise, AAR and IP, etc.). Any exercise planned or conducted during the grant period of
performance should be reported on the Exercise Data Table. Applicants/recipients are not required to
report EMPG Program-funded personnel costs associated with exercises. Data from the Exercise Data
Table should also be completed and submitted to FEMA as a component of quarterly reporting on grant
activities. The data requirements are defined in the section below. Upon entering the project name or
number in the template, the cells located to the right of the main Exercise Data Table will auto-populate
the associated priority, mission area, capabilities, and functional areas based on the project data included
in the Grant Activities Outline.
Exercise Data Table Template
Project
Number
Project
Name
Name of
Exercise
Scheduled
Date
Date
Exercise
Conducted
/Complete
d
Type of
Exercise
Exercise
Fulfills
Progressive
Exercise
Requirement
(Y/N)
Exercise
Identifie
d in IPP
(Y/N)
Date AAR
submitted
to FEMA
Exercise Data Table Definitions:
• Column 1 – Project Number from the Grant Activities Outline
• Column 2 – Project Name from the Grant Activities Outline
• Column 3 – Exercise Name
• Column 4 – Scheduled date of exercise
• Column 5 – Date exercise conducted/completed
• Column 6 – Type of exercise (select from drop-down menu)
• Column 7 – Is the exercise part of a progressive exercise series?
• Column 8 – Is exercise identified in the multi-year IPP?
• Column 9– When was the AAR submitted to FEMA?
1
FY 2022 HSGP NOFO Back to the Top
The Department of Homeland Security (DHS)
Notice of Funding Opportunity (NOFO)
Fiscal Year 2022 Homeland Security Grant
Program
Effective April 4, 2022, the Federal Government transitioned from using the Data Universal
Numbering System or DUNS number, to a new, non-proprietary identifier known as a Unique
Entity Identifier or UEI. For entities that have an active registration in SAM.gov prior to the April
4 date, the UEI has automatically been assigned and no action is necessary. For all entities filing a
new registration in SAM.gov on or after April 4, 2022, the UEI will be assigned to that Entity as
part of the SAM.gov registration process.
Unique Entity Identifier registration information is available on GSA.gov at: Unique Entity
Identifier Update | GSA.
Grants.gov registration information can be found at:
https://www.grants.gov/web/grants/register.html. Detailed information regarding UEI and SAM is
also provided in Section D of this NOFO.
Additional Information can be found on Grants.gov:
https://www.grants.gov/web/grants/forms/planned-uei-updates.html
Table of Contents
A.Program Description ............................................................................................................... 3
1.Issued By ........................................................................................................................... 3
2.Assistance Listings Number ............................................................................................. 3
3.Assistance Listings Title ................................................................................................... 3
4.Funding Opportunity Title .............................................................................................. 3
5.Funding Opportunity Number ........................................................................................ 3
6. Authorizing Authority for Program ............................................................................... 3
7.Appropriation Authority for Program ........................................................................... 3
8.Announcement Type ........................................................................................................ 3
9. Program Category ............................................................................................................ 3
10. Program Overview, Objectives, and Priorities .............................................................. 3
11.Performance Measures .................................................................................................. 10
B.Federal Award Information ................................................................................................. 11
1. Available Funding for the NOFO: $1,120,000,000 .................................................... 11
2.Projected Number of Awards: 56 .............................................................................. 14
3.Period of Performance: 36 months ........................................................................... 14
4.Projected Period of Performance Start Date(s): 09/01/2022 ...................................... 14
5.Projected Period of Performance End Date(s): 08/31/2025 ........................................ 14
6.Funding Instrument Type: Grant .............................................................................. 14
C.Eligibility Information .......................................................................................................... 15
1.Eligible Applicants .......................................................................................................... 15
2
FY 2022 HSGP NOFO Back to the Top
2.Applicant Eligibility Criteria ......................................................................................... 15
3.Other Eligibility Criteria ............................................................................................... 15
4.Cost Share or Match ...................................................................................................... 16
D.Application and Submission Information ........................................................................... 16
1.Key Dates and Times ...................................................................................................... 16
2.Agreeing to Terms and Conditions of the Award ........................................................ 18
3.Address to Request Application Package ..................................................................... 18
4.Steps Required to Obtain a Unique Entity Identifier, Register in the System for
Award Management (SAM), and Submit an Application ........................................... 18
5.Electronic Delivery ......................................................................................................... 19
6. How to Register to Apply through Grants.gov ............................................................ 19
7. How to Submit an Initial Application to FEMA via Grants.gov ................................ 19
8.Submitting the Final Application in ND Grants .......................................................... 20
9.Timely Receipt Requirements and Proof of Timely Submission ................................ 20
10.Content and Form of Application Submission ............................................................. 20
11.Other Submission Requirements .................................................................................. 29
12.Intergovernmental Review ............................................................................................ 30
13.Funding Restrictions and Allowable Costs .................................................................. 30
E.Application Review Information .......................................................................................... 39
1.Application Evaluation Criteria .................................................................................... 39
2.Review and Selection Process ........................................................................................ 41
F.Federal Award Administration Information ...................................................................... 44
1.Notice of Award .............................................................................................................. 44
2.Pass-Through Requirements ......................................................................................... 44
3.Administrative and National Policy Requirements ..................................................... 46
4.Reporting ......................................................................................................................... 48
5.Monitoring and Oversight ............................................................................................. 49
G.DHS Awarding Agency Contact Information ..................................................................... 49
1. Contact and Resource Information ............................................................................... 49
2.Systems Information ...................................................................................................... 50
H.Additional Information ......................................................................................................... 50
1.Termination Provisions .................................................................................................. 50
2. Program Evaluation ....................................................................................................... 51
3.Period of Performance Extensions ................................................................................ 51
3
FY 2022 HSGP NOFO Back to the Top
A.Program Description
1.Issued By
U.S. Department of Homeland Security (DHS)/Federal Emergency Management Agency
(FEMA)/Grant Programs Directorate (GPD)
2.Assistance Listings Number
97.067
3.Assistance Listings Title
Homeland Security Grant Program
4.Funding Opportunity Title
Fiscal Year 2022 Homeland Security Grant Program (HSGP)
•State Homeland Security Program (SHSP)
•Urban Area Security Initiative (UASI)
•Operation Stonegarden (OPSG)
5.Funding Opportunity Number
DHS-22-GPD-067-000-02
6.Authorizing Authority for Program
Section 2002 of the Homeland Security Act of 2002 (Pub. L. No. 107-296, as amended) (6
U.S.C. § 603)
7.Appropriation Authority for Program
Department of Homeland Security Appropriations Act, 2022 (Pub. L. No. 117-103)
8.Announcement Type
Initial
9. Program Category
Preparedness: Community Security
10. Program Overview, Objectives, and Priorities
a.Overview
The Fiscal Year (FY) 2022 Homeland Security Grant Program (HSGP) is one of three grant
programs that constitute the DHS/FEMA focus on enhancing the ability of state, local, tribal,
and territorial governments, as well as nonprofits, to prevent, protect against, respond to, and
recover from terrorist attacks. These grant programs are part of a comprehensive set of
measures authorized by Congress and implemented by DHS to help strengthen the Nation’s
communities against potential terrorist attacks. Among the five basic homeland security
missions noted in the DHS Strategic Plan, the HSGP supports the goal to Strengthen National
Preparedness and Resilience.
In FY 2022, there are three components of the HSGP:
4
FY 2022 HSGP NOFO Back to the Top
1)State Homeland Security Program (SHSP): SHSP assists state, local, tribal, and
territorial (SLTT) efforts to build, sustain, and deliver the capabilities necessary to
prevent, prepare for, protect against, and respond to acts of terrorism.
2)Urban Area Security Initiative (UASI): UASI assists high-threat, high-density Urban
Area efforts to build, sustain, and deliver the capabilities necessary to prevent, prepare
for, protect against, and respond to acts of terrorism.
3)Operation Stonegarden (OPSG): OPSG supports enhanced cooperation and
coordination among Customs and Border Protection (CBP), United States Border Patrol
(USBP), and federal, state, local, tribal, and territorial law enforcement agencies to
improve overall border security. OPSG provides funding to support joint efforts to secure
the United States’ borders along routes of ingress/egress to and from international
borders, to include travel corridors in states bordering Mexico and Canada, as well as
states and territories with international water borders. SLTT law enforcement agencies
utilize their inherent law enforcement authorities to support the border security mission
and do not receive any additional authority as a result of participation in OPSG.
The 2022-2026 FEMA Strategic Plan outlines three goals designed to position FEMA to
address the increasing range and complexity of disasters, support the diversity of communities
we serve, and complement the nation’s growing expectations of the emergency management
community. The HSGP supports FEMA’s efforts to achieve equitable outcomes for those we
serve (Goal 1) and to promote and sustain a prepared nation (Goal 3). We invite our
stakeholders and partners to also adopt these priorities and join us in building a more prepared
and resilient nation.
Finally, for FY 2022, DHS is focused on the criticality of information sharing and
collaboration to building a national culture of preparedness and protecting against terrorism
and other threats to our national security. The threats to our nation have evolved during the
past two decades. We now face continuous cyber threats by sophisticated actors, threats to soft
targets and crowded places, and threats from domestic violent extremists who currently pose
the greatest terrorism threat to the nation 1. Therefore, for FY 2022, DHS has identified six
priority areas related to the most serious threats to the nation. Recipients are expected to
address those priority areas with their HSGP funds.
b.Objective
The objective of the FY 2022 HSGP is to fund SLTT efforts to prevent terrorism and prepare
the Nation for threats and hazards that pose the greatest risk to the security of the United
States.
c.Priorities
SHSP and UASI Funding Priorities
Given the evolving national security threat landscape, DHS/FEMA has evaluated the national
risk profile and set priorities that help inform appropriate allocation of scarce security dollars.
In assessing the national risk profile for FY 2022, six priority areas attract the most concern.
Due to the unique threats that the nation faces in 2022, DHS/FEMA has determined that
1 Strategic Intelligence Assessment and Data on Domestic Terrorism, Federal Bureau of Investigation and Department
of Homeland Security, May 2021.
5
FY 2022 HSGP NOFO Back to the Top
recipients should allocate a total of 30 percent of their SHSP and UASI award funds across
these six priority areas. As indicated below, four of the priorities have minimum spend
requirements totaling 12 percent of SHSP and UASI awards. Recipients will have the
flexibility to allocate the remaining 18 percent across the priorities. The following are the six
priority areas for FY 2022, along with the minimum corresponding percentage of SHSP and
UASI funds that each recipient will be required to allocate:
1) Enhancing the protection of soft targets/crowded places – 3 percent
2) Enhancing information and intelligence sharing and analysis – 3 percent
3) Combating domestic violent extremism – 3 percent
4) Enhancing cybersecurity – no minimum percent
5) Enhancing community preparedness and resilience – 3 percent
6) Enhancing election security – no minimum percent
Additional information about these priority areas and how they relate to achieving anti-
terrorism capabilities is included in Section D.10.b.II of this NOFO. Failure by a recipient to
propose investments and projects that align with the priority areas and spending requirements
will result in a recipient having a portion of their SHSP and UASI funds (up to 30 percent)
placed on hold until they provide projects that sufficiently align to the National Priority Areas,
and total at least the minimum percentages per National Priority Area priority area (as
applicable) and overall 30 percent of total SHSP and UASI funds.
A state or high-risk urban area must allocate the remaining 70 percent of their funding to gaps
identified through their Threat and Hazard Identification and Risk Assessment (THIRA) and
Stakeholder Preparedness Review (SPR) process.
Likewise, there are several enduring security needs that crosscut the homeland security
enterprise to which recipients should consider allocating funding across core capability gaps
and national priorities. The following are enduring needs that help recipients implement a
comprehensive approach to securing communities:
1) Effective planning 2
2) Training and awareness campaigns
3) Equipment and capital projects
4) Exercises
The table below provides a breakdown of the FY 2022 SHSP and UASI priorities (the focus of
OPSG remains unique to border security), showing the core capabilities enhanced and lifelines
supported, as well as examples of eligible project types for each area. A detailed description of
allowable investments for each project type is included in the Preparedness Grants Manual.
DHS/FEMA anticipates that in future years, national priorities will continue to be included and
will be updated as the threats evolve and as capability gaps are closed. Applicants are strongly
encouraged to begin planning to sustain existing capabilities through funding mechanisms
other than DHS preparedness grants. The example project types in the table below are
allowable to prepare for disasters unrelated to acts of terrorism as long as they also help
2 Including assessment of critical infrastructure system vulnerabilities and plans to reduce consequences of disruptions,
using the Infrastructure Resilience Planning Framework and Regional Resiliency Assessment Methodology produced
by the Cybersecurity and Infrastructure Security Agency.
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achieve target capabilities related to preventing, preparing for, protecting against, or
responding to acts of terrorism.
FY 2022 SHSP and UASI Funding Priorities
Priority Areas Core Capabilities Lifelines Example Project Types
National Priorities
Enhancing
Cybersecurity
•Cybersecurity
•Intelligence and information
sharing
•Planning
•Public information and
warning
•Operational coordination
•Screening, search, and
detection
•Access control and identity
verification
•Supply chain integrity and
security
•Risk management for
protection programs and
activities
•Long-term vulnerability
reduction
•Situational assessment
•Infrastructure systems
•Operational communications
•Safety and
Security
•Cybersecurity risk assessments
•Migrating online services to the “.gov”
internet domain
•Projects that address vulnerabilities
identified in cybersecurity risk
assessments
o Improving cybersecurity of critical
infrastructure to meet minimum levels
identified by the Cybersecurity and
Infrastructure Security Agency
(CISA), and the National Institute of
Standards and Technology
Cybersecurity Framework
o Cybersecurity training and planning
Enhancing the
Protection of
Soft Targets/
Crowded Places
•Operational coordination
•Public information and
warning
•Intelligence and information
sharing
•Interdiction and disruption
•Screening, search, and
detection
•Access control and identity
verification
•Physical protective measures
•Risk management for
protection programs and
activities
•Safety and
Security
•Operational overtime
•Physical security enhancements
o Closed-circuit television (CCTV)
security cameras
o Security screening equipment for
people and baggage
o Lighting
o Access controls
o Fencing, gates, barriers, etc.
•Unmanned aircraft system detection
technologies
Enhancing
information and
intelligence
sharing and
analysis
•Intelligence and information
sharing
•Interdiction and disruption
•Planning
•Public information and
warning
•Operational coordination
•Risk management for
protection programs and
activities
•Safety and
Security
•Fusion center operations (Fusion Center
project will be required under this
investment, no longer as a stand-alone
investment)
•Information sharing with all DHS
components; fusion centers; other
operational, investigative, and analytic
entities; and other federal law
enforcement and intelligence entities
•Cooperation with DHS officials and other
entities designated by DHS in
intelligence, threat recognition,
assessment, analysis, and mitigation
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FY 2022 HSGP NOFO Back to the Top
Priority Areas Core Capabilities Lifelines Example Project Types
• Identification, assessment, and reporting
of threats of violence
• Joint intelligence analysis training and
planning with DHS officials and other
entities designated by DHS
Combating
Domestic
Violent
Extremism
• Interdiction and disruption
• Intelligence and information
sharing
• Planning
• Public information and
warning
• Operational coordination
• Risk management for
protection programs and
activities
• Safety and
Security
• Open-source analysis of disinformation
and misinformation campaigns, targeted
violence and threats to life, including
tips/leads, and online/social media-based
threats
• Sharing and leveraging intelligence and
information, including open-source
analysis
• Execution and management of threat
assessment programs to identify, evaluate,
and analyze indicators and behaviors
indicative of domestic violent extremists
• Training and awareness programs (e.g.,
through social media, suspicious activity
reporting [SAR] indicators and behaviors)
to help prevent radicalization
• Training and awareness programs (e.g.,
through social media, SAR indicators and
behaviors) to educate the public on
misinformation and disinformation
campaigns and resources to help them
identify and report potential instances of
domestic violent extremism
Enhancing
Community
Preparedness and
Resilience
• Planning
• Public Information and
Warning
• Community Resilience
• Risk Management for
Protection Programs and
Activities
• Mass Care Services
• Intelligence and Information
Sharing
• Risk and Disaster Resilience
Assessment
• Long Term Vulnerability
Reduction
• Safety and
Security
• Establish, train, and maintain Community
Emergency Response Teams (CERT) and
Teen CERT, with a focus on historically
undeserved communities, including
procurement of appropriate tools,
equipment and training aides
o Local delivery of CERT Train-the-
Trainer and CERT Program Manager
to build local program training and
maintenance capacity
• Provide continuity training, such as
FEMA’s Organizations Preparing for
Emergency Needs training, to faith-based
organizations, local businesses, and
community-based organizations such as
homeless shelters, food pantries, nonprofit
medical providers and senior care
facilities to bolster their resilience to all
hazards
• Partner with local school districts to
deliver the Student Tools for Emergency
Planning curriculum or other educational
programming to guide students on how to
create emergency kits and family
communications plans
• Partner with key stakeholders to assist
with completing the Emergency Financial
First Aid Kit or a similar tool to bolster
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FY 2022 HSGP NOFO Back to the Top
Priority Areas Core Capabilities Lifelines Example Project Types
the disaster centric financial resilience of
individuals and households
• Execute You are the Help Until the Help
Arrives workshops in concert with
community-based organizations to bolster
individual preparedness
• Target youth preparedness using FEMA
programing such as Prepare with Pedro
resources and Ready2Help
• Promote community planning,
coordination, and integration of children’s
needs during emergencies through
workshops like FEMA’s Integrating the
Needs of Children
• Community Mapping: identify
community resources and characteristics
in order to identify gaps in resources,
identify hazards and vulnerabilities, and
inform action to promote resilience
• Provide training and awareness programs
with key stakeholders (e.g., through social
media, community and civic
organizations) to educate the public on
misinformation and disinformation
campaigns to increase individual and
community resilience.
Enhancing
Election Security • Cybersecurity
• Intelligence and
information sharing
• Planning
• Long-term vulnerability
reduction
• Situational assessment
• Infrastructure systems
• Safety and
Security
• Physical security planning support
• Physical/site security measures – e.g.,
locks, shatter proof glass, alarms, etc.
• General election security navigator
support
• Cyber navigator support
• Cybersecurity risk assessments, training,
and planning
• Projects that address vulnerabilities
identified in cybersecurity risk
assessments
• Iterative backups, encrypted backups,
network segmentation, software to
monitor/scan, and endpoint protection
• Distributed Denial Of Service protection
• Migrating online services to the “.gov”
internet domain
Enduring Needs
Planning • Planning
• Risk management for
protection programs and
activities
• Risk and disaster resilience
assessment
• Threats and hazards
identification
• Operational coordination
• Community resilience
• Safety and
Security
• Development of:
o Security Risk Management Plans
o Threat Mitigation Plans
o Continuity of Operations Plans
o Response Plans
• Efforts to strengthen governance
integration between/among regional
partners
• Joint training and planning with DHS
officials and other entities designated by
DHS
• Cybersecurity training and planning
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FY 2022 HSGP NOFO Back to the Top
Priority Areas Core Capabilities Lifelines Example Project Types
• Revision of existing plans to strengthen
community resilience in underserved
communities
Training &
Awareness • Long-term vulnerability
reduction
• Public information and
warning
• Operational coordination
• Situational assessment
• Community resilience
• Safety and
Security
• Active shooter training
• Intelligence analyst training
• SAR and terrorism indicators/behaviors
training
• Security training for employees
• Public awareness/preparedness campaigns
• Joint training and planning with DHS
officials and other entities designated by
DHS
• Cybersecurity training and planning
• Sharing and leveraging intelligence and
information
• Targeted outreach and preparedness
training for underserved communities in
conjunction with community-based
organizations
Equipment &
Capital Projects
• Long-term vulnerability
reduction
• Infrastructure systems
• Operational communications
• Interdiction and disruption
• Screening, search and
detection
• Access control and identity
verification
• Physical protective measures
• Safety and
Security
• Protection of high-risk, high-consequence
areas or systems that have been identified
through risk assessments
• Physical security enhancements
o Security cameras (CCTV)
o Security screening equipment for
people and baggage
o Lighting
o Access Controls
Fencing, gates, barriers, etc.
• Enhancing Weapons of Mass Destruction
(WMD) and/or improvised explosive
device (IED) prevention, detection,
response and recovery capabilities
o Chemical/Biological/Radiological/
Nuclear/Explosive (CBRNE)
detection, prevention, response, and
recovery equipment
Exercises • Long-term vulnerability
reduction
• Operational coordination
• Operational communications
• Community resilience
• Safety and
Security
• Response exercises, including exercise
planning with community-based
organizations
For FY 2022, each SHSP and UASI recipient is required to submit an Investment Justification
(IJ) for the four National Priority Areas with associated minimum spend requirements. Each of
these four investments must also account for at least the relevant minimum percentage (12
percent) of the applicant’s SHSP and UASI allocation. State Administrative Agencies (SAAs)
may submit complete project-level information at the time of application, including the
National Priority Area IJs, but are not required to do so. As a reminder, all SHSP- and
UASI-funded projects must have a demonstrated nexus to achieving target capabilities
related to preventing, preparing for, protecting against, and responding to acts of
terrorism. However, such projects may simultaneously support enhanced preparedness for
disasters unrelated to acts of terrorism.
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FY 2022 HSGP NOFO Back to the Top
DHS/FEMA also requires SHSP and UASI recipients (states, territories, and high-risk urban
areas) to complete a THIRA/SPR and prioritize grant funding to support closing capability
gaps or sustaining capabilities that address national priorities and/or support enduring needs.
Additional information on the THIRA/SPR process, including other National Preparedness
System (NPS) tools and resources, can be found at https://www.fema.gov/national-
preparedness-system. Detailed information on THIRA/SPR timelines and deadlines can be
found in the Preparedness Grants Manual.
OPSG Funding Priorities
The table below provides a breakdown of the FY 2022 OPSG funding priority, which remains
focused on and unique to border security.
FY 2022 OPSG Funding Priority
Priority Areas Core Capabilities Lifelines Example Project Types
National Priorities
Enhancing
information and
intelligence
sharing and
analysis, and
cooperation with
federal agencies,
including DHS
• Intelligence and
information sharing
• Safety and
Security
• Participation in the DHS/ICE 287(g)
training program
• Information sharing with all DHS
components; fusion centers; other
operational, investigative, and analytic
entities; and other federal law
enforcement and intelligence entities
• Cooperation with DHS officials and other
entities designated by DHS in
intelligence, threat recognition,
assessment, analysis, and mitigation
• Identification, assessment, and reporting
of threats of violence
• Joint intelligence analysis training and
planning with DHS officials and other
entities designated by DHS
For FY 2022, each OPSG applicant is required to clearly articulate and identify how the
Concept of Operations addresses the national priority identified above.
11. Performance Measures
Performance metrics for this program:
SHSP and UASI:
• Percentage of funding allocated by the recipient to core capabilities to build or sustain
national priorities identified in the section above
• Percentage of funding and projects allocated by the recipient that align to capability
gaps identified through the THIRA/SPR process
• Percentage of projects identified by the recipient that address a capability gap in a core
capability that has a target(s) rated as high
FEMA will calculate and analyze the above metrics through a review of state/territory and
urban area SPR submissions and required programmatic reports.
OPSG:
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FY 2022 HSGP NOFO Back to the Top
• Number of contacts that occurred as a result of OPSG deployments
o Number of arrests that resulted from OPSG contacts
o Value of drug seizures that resulted from OPSG contacts
B. Federal Award Information
1. Available Funding for the NOFO: $1,120,000,000
HSGP Programs FY 2022 Allocation
SHSP $415,000,000
UASI $615,000,000
OPSG $90,000,000
Total $1,120,000,000
SHSP Allocations
For FY 2022, DHS/FEMA will award SHSP funds based on DHS/FEMA’s relative risk
methodology and statutory minimums pursuant to the Homeland Security Act of 2002, as
amended. THIRA/SPR results do not impact grant allocations or awards.
Each state and territory will receive a minimum allocation under the SHSP using thresholds
established in the Homeland Security Act of 2002, as amended. All 50 States, the District of
Columbia, and the Commonwealth of Puerto Rico will receive 0.35 percent of the total funds
allocated for grants under Section 2003 and Section 2004 of the Homeland Security Act of
2002, as amended. Each of the four territories (American Samoa, Guam, the Northern Mariana
Islands, and the U.S. Virgin Islands) will receive a minimum allocation of 0.08 percent of the
total funds allocated for grants under Section 2003 and 2004 of the Homeland Security Act of
2002, as amended.
Each state must include a separate IJ for each of the four National Priority Areas with a
minimum spend requirement. All projects related to the minimum spend for the National
Priority Area must be included in the IJ. For the National Priority Areas that have a
minimum spend percentage requirement, the funding level in each of those National Priority
Area investments must equal or exceed the percentage for that respective National Priority
Area, calculated as a percentage of the state’s SHSP allocation in the table below. The funding
levels across all six National Priority Areas must equal or exceed 30 percent of the total SHSP
allocation.
FY 2022 SHSP ALLOCATIONS
State/Territory FY 2022
Allocation
State/Territory FY 2022
Allocation
Alabama $4,847,500 Montana $4,847,500
Alaska $4,847,500 Nebraska $4,847,500
American Samoa 1,108,000 Nevada $4,847,500
Arizona $4,847,500 New Hampshire $4,847,500
Arkansas $4,847,500 New Jersey $7,074,841
California $57,035,623 New Mexico $4,847,500
Colorado $4,847,500 New York $68,033,267
Connecticut $4,847,500 North Carolina $5,085,387
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State/Territory FY 2022
Allocation
State/Territory FY 2022
Allocation
Delaware $4,847,500 North Dakota $4,847,500
District of Columbia $5,085,387 Northern Mariana Islands $1,108,000
Florida $9,343,905 Ohio $6,190,947
Georgia $5,288,656 Oklahoma $4,847,500
Guam $1,108,000 Oregon $4,847,500
Hawaii $4,847,500 Pennsylvania $8,136,252
Idaho $4,847,500 Puerto Rico $4,847,500
Illinois $13,894,910 Rhode Island $4,847,500
Indiana $4,847,500 South Carolina $4,847,500
Iowa $4,847,500 South Dakota $4,847,500
Kansas $4,847,500 Tennessee $4,847,500
Kentucky $4,847,500 Texas $18,210,451
Louisiana $4,847,500 U.S. Virgin Islands $1,108,000
Maine $4,847,500 Utah $4,847,500
Maryland $7,074,841 Vermont $4,847,500
Massachusetts $6,190,947 Virginia $8,136,252
Michigan $5,085,387 Washington $6,190,947
Minnesota $4,847,500 West Virginia $4,847,500
Mississippi $4,847,500 Wisconsin $4,847,500
Missouri $4,847,500 Wyoming $4,847,500
Total $415,000,000
UASI Allocations
Eligible candidates for the FY 2022 UASI program are identified in the table below. Eligibility
has been determined through an analysis of relative risk of terrorism faced by the 100 most
populous Metropolitan Statistical Areas (MSAs) in the United States, in accordance with the
Homeland Security Act of 2002, as amended. Detailed information on MSAs is publicly
available from the United States Census Bureau at https://www.census.gov/programs-
surveys/metro-micro.html. THIRA/SPR results do not impact grant allocations or awards.
The following table identifies the UASI allocations for each high-risk urban area based on
DHS/FEMA’s relative risk methodology pursuant to the Homeland Security Act of 2002, as
amended.
In its application, each high-risk urban area, through the state, must include a separate IJ for
each of the four National Priority Areas with minimum spend requirements. All projects
related to the minimum spend for the National Priority Area must be included in the IJ.
For the National Priority Areas that have a minimum spend percentage requirement, the funding
level in each of those National Priority Area investments must equal or exceed the percentage
for that respective National Priority Area, calculated as a percentage of the urban area’s UASI
allocation in the table below. The funding levels across all six National Priority Areas must
equal or exceed 30 percent of the total UASI allocation.
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FY 2022 UASI ALLOCATIONS
State/Territory Urban Area FY 2022 UASI Allocation
Arizona Phoenix Area $5,250,000
California
Anaheim/Santa Ana Area $5,250,000
Bay Area $37,049,000
Los Angeles/Long Beach Area $67,182,000
Riverside Area $3,900,000
Sacramento Area $3,800,000
San Diego Area $16,696,000
Colorado Denver Area $3,900,000
District of Columbia National Capital Region $51,127,000
Florida
Miami/Fort Lauderdale Area $14,750,000
Orlando Area $3,800,000
Tampa Area $3,800,000
Georgia Atlanta Area $6,700,000
Illinois Chicago Area $67,182,000
Indiana Indianapolis Area $1,500,000
Louisiana New Orleans Area $1,500,000
Maryland Baltimore Area $3,800,000
Massachusetts Boston Area $16,900,000
Michigan Detroit Area $5,250,000
Minnesota Twin Cities Area $5,250,000
Missouri Kansas City Area $1,500,000
St. Louis Area $3,800,000
Nevada Las Vegas Area $5,250,000
New Jersey Jersey City/Newark Area $18,915,000
New York New York City Area $176,599,000
North Carolina Charlotte Area $3,800,000
Ohio Cincinnati Area $1,500,000
Cleveland Area $1,500,000
Oregon Portland Area $3,800,000
Pennsylvania Philadelphia Area $16,900,000
Pittsburgh Area $1,500,000
Texas
Dallas/Fort Worth/Arlington Area $16,900,000
Houston Area $24,600,000
San Antonio Area $3,800,000
Virginia Hampton Roads Area $3,800,000
Washington Seattle Area $6,250,000
Total $615,000,000
OPSG Allocations
For FY 2022, DHS/FEMA will award OPSG funds based on risk and the anticipated
effectiveness of the proposed use of grant funds upon completion of the application review
process. The FY 2022 OPSG risk assessment is designed to identify the risk to border security
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FY 2022 HSGP NOFO Back to the Top
and to assist with the distribution of funds for the grant program. Funding under OPSG is
distributed based on the risk to the security of the border and the effectiveness of the proposed
projects. Entities eligible for funding are the state, local, and tribal law enforcement agencies
that are located along the border of the United States. DHS/FEMA will make final award
determinations based upon a review of the anticipated effectiveness of the state’s application as
described in Section D, below. The THIRA/SPR process is not required for OPSG.
For the purposes of OPSG, the risk is defined as the potential for an adverse outcome assessed
as a function of threats, vulnerabilities, and consequences associated with an incident, event, or
occurrence.
Based upon ongoing intelligence analysis and extensive security reviews, DHS/CBP continues
to focus the bulk of OPSG funds based upon risk analyses. The risk model used to allocate
OPSG funds considers the potential risk that certain threats pose to border security and
estimates the relative risk faced by a given area. In evaluating risk, DHS/CBP considers
intelligence, situational awareness, criminal trends, and statistical data specific to each of the
border sectors, and the potential impacts that these threats pose to the security of the border
area. For vulnerability and consequence, DHS/CBP considers the expected impact and
consequences of successful border events occurring in specific areas.
Threat and vulnerability are evaluated based on specific operational data from DHS/CBP.
Threat components present in each of the sectors are used to determine the overall threat score.
These components are terrorism, criminal aliens, drug trafficking organizations, and alien
smuggling organizations.
Effectiveness of the proposed investments will be evaluated based on the recipient’s
investment strategy, budget, collaboration, and past performance.
2. Projected Number of Awards: 56
3. Period of Performance: 36 months
Extensions to the period of performance are allowed. For additional information on period of
performance extensions, please refer to Section H of this NOFO and the Preparedness Grants
Manual.
FEMA awards under most programs, including this program, only include one
budget period, so it will be same as the period of performance. See 2 C.F.R. § 200.1
for definitions of “budget period” and “period of performance.”
4. Projected Period of Performance Start Date(s): September 1, 2022
5. Projected Period of Performance End Date(s): August 31, 2025
6. Funding Instrument Type: Grant
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C. Eligibility Information
1. Eligible Applicants
The SAA is the only entity eligible to submit HSGP applications to DHS/FEMA, including
those applications submitted on behalf of UASI and OPSG applicants. All 56 states and
territories, including any state of the United States, the District of Columbia, the
Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, and the
Commonwealth of the Northern Mariana Islands, are eligible to apply for SHSP funds. Tribal
governments may not apply directly for HSGP funding; however, funding may be available to
tribes under SHSP and OPSG through the SAA.
2. Applicant Eligibility Criteria
Eligible high-risk urban areas for the FY 2022 UASI program have been determined through
an analysis of relative risk of terrorism faced by the 100 most populous MSAs in the United
States. Subawards will be made by the SAAs to the designated high-risk urban areas.
In FY 2022, OPSG eligible subrecipients are local units of government at the county level or
equivalent level of government and federally recognized tribal governments in states
bordering Canada or Mexico and states and territories with international water borders. All
applicants must have active ongoing USBP operations coordinated through a CBP sector
office to be eligible for OPSG funding.
In FY 2022, OPSG subrecipients eligible to apply for and receive a subaward directly from the
SAAs are divided into three Tiers. Tier 1 entities are local units of government at the county
level or equivalent and federally recognized tribal governments that are on a physical border in
states bordering Canada, states bordering Mexico, and states and territories with international
water borders. Tier 2 eligible subrecipients are those not located on the physical border or
international water but are contiguous to a Tier 1 county. Tier 3 eligible subrecipients are
those not located on the physical border or international water but are contiguous to a Tier 2
eligible subrecipient. The tier structure is only applicable with regard to eligibility. OPSG
funding allocations are based on the assessed border security risks as determined by the
USBP.
An application submitted by an otherwise eligible non-federal entity (i.e., the applicant) may
be deemed ineligible when the person that submitted the application is not: 1) a current
employee, personnel, official, staff, or leadership of the non-federal entity; and 2) duly
authorized to apply for an award on behalf of the non-federal entity at the time of application.
Further, the Authorized Organization Representative (AOR) must be a duly authorized current
employee, personnel, official, staff, or leadership of the recipient and provide an email
address unique to the recipient at the time of application and upon any change in
assignment during the period of performance. Consultants or contractors of the recipient
are not permitted to be the AOR of the recipient.
3. Other Eligibility Criteria
a. National Incident Management System (NIMS) Implementation
Prior to allocation of any federal preparedness awards, recipients must ensure and maintain
adoption and implementation of NIMS. The list of objectives used for progress and
achievement reporting is on FEMA’s website at https://www.fema.gov/emergency-
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FY 2022 HSGP NOFO Back to the Top
managers/nims/implementation-training.
Please see the Preparedness Grants Manual for more information on NIMS.
b. Emergency Management Assistance Compact (EMAC) Membership
In support of the National Preparedness Goal (the Goal), SHSP recipients must belong to, be
in, or act as a temporary member of EMAC, except for American Samoa and the
Commonwealth of the Northern Mariana Islands, which are not required to belong to EMAC
at this time. All assets supported in part or entirely with FY 2022 HSGP funding must be
readily deployable and NIMS-typed, when possible, to support emergency or disaster
operations per existing EMAC agreements. In addition, funding may be used for the
sustainment of core capabilities that, while they may not be physically deployable, support
national response capabilities, such as Geographic/Geospatial Information Systems (GIS),
interoperable communications systems, capabilities as defined under the Mitigation Mission
Area of the Goal, and fusion centers.
c. Law Enforcement Terrorism Prevention Activities (LETPA)
Per section 2006 of the Homeland Security Act of 2002, as amended (6 U.S.C. § 607),
DHS/FEMA is required to ensure that at least 25 percent of grant funding appropriated for
grants awarded under HSGP’s authorizing statute are used for LETPAs. For FY 2022,
DHS/FEMA is requiring that at least 30 percent of grant funding appropriated under
HSGP is used for LETPA. DHS/FEMA meets this requirement, in part, by requiring all
recipients allocate at least 30 percent of the combined HSGP funds allocated under SHSP and
UASI towards LETPAs, as defined in 6 U.S.C. § 607. The LETPA allocation can be from
SHSP, UASI, or both. The 30 percent LETPA allocation may be met by funding projects in
any combination of the six National Priority Areas identified above and any other investments.
The 30 percent LETPA allocation requirement is in addition to the 80 percent pass-through
requirement to local units of government and tribes, referenced below. The Preparedness
Grants Manual includes additional information on project selection considerations and
allowable activities for LETPA investments.
The National Prevention Framework describes those activities that should be executed upon
the discovery of intelligence or information regarding an imminent threat to the homeland, to
thwart an initial or follow-on terrorist attack and provides guidance to ensure the Nation is
prepared to identify, prevent, avoid, or stop a threatened or actual act of terrorism. Activities
outlined in the National Prevention Framework are eligible for use as LETPA-focused funds.
Also, where capabilities are shared with the protection mission area, the National Protection
Framework activities are also eligible. All other terrorism prevention activities proposed for
funding under LETPA must be approved by the FEMA Administrator.
4. Cost Share or Match
There is no cost share or match requirement for the FY 2022 HSGP.
D. Application and Submission Information
1. Key Dates and Times
a. Application Start Date: May 13, 2022
b. Application Submission Deadline: June 13, 2022 at 5 p.m. ET
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All applications must be received by the established deadline. The Non-Disaster (ND) Grants
System has a date stamp that indicates when an application is submitted. Applicants will
receive an electronic message confirming receipt of their submission. For additional
information on how an applicant will be notified of application receipt, see the subsection
titled “Timely Receipt Requirements and Proof of Timely Submission” in Section D of this
NOFO.
FEMA will not review applications that are received after the deadline or consider these
late applications for funding. FEMA may, however, extend the application deadline on
request for any applicant who can demonstrate that good cause exists to justify extending the
deadline. Good cause for an extension may include technical problems outside of the
applicant’s control that prevent submission of the application by the deadline, other exigent or
emergency circumstances, or statutory requirements for FEMA to make an award.
Applicants experiencing technical problems outside of their control must notify FEMA
as soon as possible and before the application deadline. Failure to timely notify FEMA of
the issue that prevented the timely filing of the application may preclude consideration of the
award. “Timely notification” of FEMA means prior to the application deadline and within 48
hours after the applicant became aware of the issue.
A list of FEMA contacts can be found in Section G of this NOFO, “DHS Awarding Agency
Contact Information.” For additional assistance using the ND Grants System, please contact
the ND Grants Service Desk at (800) 865-4076 or NDGrants@fema.dhs.gov. The ND Grants
Service Desk is available Monday through Friday, 9:00 AM – 6:00 PM Eastern Time (ET).
For programmatic or grants management questions, please contact your Program Analyst or
Grants Specialist. If applicants do not know who to contact or if there are programmatic
questions or concerns, please contact the Centralized Scheduling and Information Desk
(CSID) by phone at (800) 368-6498 or by e-mail at askcsid@fema.dhs.gov, Monday through
Friday, 9:00 AM – 5:00 PM ET.
c. Anticipated Funding Selection Date: No later than August 17, 2022
d. Anticipated Award Date: No later than September 30, 2022
e. Other Key Dates:
Event Suggested Deadline for Completion
Obtaining UEI number Four weeks before actual submission deadline
Obtaining a valid Employer
Identification Number (EIN) Four weeks before actual submission deadline
Creating an account with login.gov Four weeks before actual submission deadline
Registering in SAM or Updating
SAM registration Four weeks before actual submission deadline
Registering in Grants.gov Four weeks before actual submission deadline
Starting application in Grants.gov One week before actual submission deadline
Submitting the final application in
ND Grants By the submission deadline
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2. Agreeing to Terms and Conditions of the Award
By submitting an application, applicants agree to comply with the requirements of this NOFO
and the terms and conditions of the award, should they receive an award.
3. Address to Request Application Package
See the Preparedness Grants Manual for requesting and submitting an application.
Initial applications are processed through the Grants.gov portal. Final applications are
completed and submitted through FEMA’s Non-Disaster Grants (ND Grants) System.
Application forms and instructions are available at Grants.gov. To access these materials, go
to http://www.grants.gov.
Hard copies of the NOFO can be downloaded at Grants.gov or obtained via email from the
Awarding Office points of contact listed in Section G of this NOFO, “DHS Awarding Agency
Contact Information” or by TTY (800) 462-7585.
4. Steps Required to Obtain a Unique Entity Identifier, Register in the System for Award
Management (SAM), and Submit an Application
Applying for an award under this program is a multi-step process and requires time to
complete. Applicants are encouraged to register early as the registration process can take four
weeks or more to complete. Therefore, registration should be done in sufficient time to ensure
it does not impact your ability to meet required submission deadlines.
Please review the table above for estimated deadlines to complete each of the steps listed.
Failure of an applicant to comply with any of the required steps before the deadline for
submitting an application may disqualify that application from funding.
To apply for an award under this program, all applicants must:
a. Apply for, update, or verify their UEI number and Employer Identification Number
(EIN) from the Internal Revenue Service;
b. In the application, provide an UEI number;
c. Have an account with login.gov;
d. Register for, update, or verify their SAM account and ensure the account is active before
submitting the application;
e. Create a Grants.gov account;
f. Add a profile to a Grants.gov account;
g. Establish an Authorized Organizational Representative (AOR) in Grants.gov;
h. Register in ND Grants
i. Submit an initial application in Grants.gov;
j. Submit the final application in ND Grants, including electronically signing
applicable forms; and
k. Continue to maintain an active SAM registration with current information at all times
during which they have an active federal award or an application or plan under
consideration by a federal awarding agency. As part of this, applicants must also provide
information on their immediate and highest-level owner and subsidiaries, as well as on all
predecessors that have been awarded federal contracts or federal financial assistance
within the last three years, if applicable.
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Specific instructions on how to apply for, update, or verify a UEI number or SAM registration
or establish an AOR are included below in the steps for applying through Grants.gov.
Applicants are advised that FEMA may not make a federal award until the applicant has
complied with all applicable SAM requirements. Therefore, an applicant’s SAM registration
must be active not only at the time of application, but also during the application review
period and when FEMA is ready to make a federal award. Further, as noted above, an
applicant’s or recipient’s SAM registration must remain active for the duration of an active
federal award. If an applicant’s SAM registration is expired at the time of application, expires
during application review, or expires any other time before award, FEMA 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.
Per 2 C.F.R. § 25.110(c)(2)(iii), if an applicant is experiencing exigent circumstances that
prevents it from obtaining an UEI number and completing SAM registration prior to receiving
a federal award, the applicant must notify FEMA as soon as possible by contacting
askcsid@fema.dhs.gov and providing the details of the circumstances that prevent completion
of these requirements. If FEMA determines that there are exigent circumstances and FEMA
has decided to make an award, the applicant will be required to obtain an UEI number, if
applicable, and complete SAM registration within 30 days of the federal award date.
5. Electronic Delivery
DHS is participating in the Grants.gov initiative to provide the grant community with a single
site to find and apply for grant funding opportunities. DHS encourages or requires applicants
to submit their applications online through Grants.gov, depending on the funding opportunity.
For this funding opportunity, FEMA requires applicants to submit initial applications through
Grants.gov and a final application through ND Grants.
6. How to Register to Apply through Grants.gov
For information on how to register to apply through Grants.gov, please see the Preparedness
Grants Manual.
7. How to Submit an Initial Application to FEMA via Grants.gov
Standard Form 424 (SF-424) is the initial application for this NOFO.
Grants.gov applicants can apply online using a workspace. A workspace is a shared, online
environment where members of a grant team may simultaneously access and edit different
web forms within an application. For each Notice of Funding Opportunity, applicants can
create individual instances of a workspace. Applicants are encouraged to submit their initial
applications in Grants.gov at least seven days before the application deadline.
In Grants.gov, applicants need to submit the following forms:
• SF-424, Application for Federal Assistance
• Grants.gov Lobbying Form, Certification Regarding Lobbying
For further information on how to submit an initial application via Grants.gov, please see the
Preparedness Grants Manual.
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8. Submitting the Final Application in ND Grants
After submitting the initial application in Grants.gov, eligible applicants will be notified by
FEMA and asked to proceed with submitting their complete application package in ND
Grants. Applicants can register early with ND Grants and are encouraged to begin their ND
Grants registration at the time of this announcement or, at the latest, seven days before the
application deadline. Early registration will allow applicants to have adequate time to start
and complete their applications.
Applicants needing assistance registering for the ND Grants system should contact
ndgrants@fema.dhs.gov or (800) 865-4076. For step-by-step directions on using the ND
Grants system and other guides, please see https://www.fema.gov/grants/guidance-tools/non-
disaster-grants-management-system.
In ND Grants, applicants will be prompted to submit the standard application information and
any program-specific information required as described in Section D.10 of this NOFO,
“Content and Form of Application Submission.” The Standard Forms (SF) are auto generated
in ND Grants, but applicants may access these forms in advance through the Forms tab under
the SF-424 family on Grants.gov. Applicants should review these forms before applying to
ensure they have all the information required.
For additional application submission requirements, including program-specific requirements,
please refer to the subsection titled “Content and Form of Application Submission” under
Section D of this NOFO.
9. Timely Receipt Requirements and Proof of Timely Submission
As application submission is a two-step process, the applicant with the AOR role who
submitted the application in Grants.gov will receive an acknowledgement of receipt and a
tracking number (GRANTXXXXXXXX) from Grants.gov with the successful transmission
of its initial application. This notification does not serve as proof of timely submission, as
the application is not complete until it is submitted in ND Grants. Applicants can also
view the ND Grants Agency Tracking Number by accessing the Details tab in the submitted
workspace section in Grants.gov, under the Agency Tracking Number column. Should the
Agency Tracking Number not appear, the application has not yet migrated from Grants.gov
into the ND Grants System. Please allow 24 hours for your ND Grants application tracking
number to migrate.
All applications must be received in ND Grants by 5:00 PM ET on the application deadline
date. Proof of timely submission is automatically recorded by ND Grants. An electronic
date/time stamp is generated within the system when the application is successfully received
by ND Grants. Additionally, the applicant(s) listed as contacts on the application will receive
a system-generated email to confirm receipt.
10. Content and Form of Application Submission
a. Standard Required Application Forms and Information
The following forms or information are required to be submitted in either Grants.gov or ND
Grants. The Standard Forms (SF) are submitted either through Grants.gov, through forms
generated in ND Grants, or as an attachment in ND Grants. Applicants may also access the SFs
at https://www.grants.gov/web/grants/forms/sf-424-family.html.
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I. GRANTS.GOV
• SF-424, Application for Federal Assistance, initial application submitted through
Grants.gov
• Grants.gov Lobbying Form, Certification Regarding Lobbying, submitted through
Grants.gov
II. ND GRANTS
• SF-424A, Budget Information (Non-Construction), submitted via the forms generated
by ND Grants
o For construction under an award, submit SF-424C, Budget Information
(Construction), submitted via the forms generated by ND Grants, in addition to or
instead of SF-424A
o To comply with 2 C.F.R. § 200.402 - 2 C.F.R. § 200.405, HSGP applicants must
complete and submit an SF-424A or SF-424C, as appropriate, reflecting cost
breakdown per budget cost categories per sub-program (SHSP, UASI, OPSG) and
Management and Administration costs as applicable to align with the SHSP and
UASI allocations and OPSG requests. The SF-424A or SF-424C with the pre-filled
requirements can be found with the HSGP NOFO and associated attachments on
grants.gov. Adjustments to the SF-424A or SF-424 C may be required after the FY
2022 OPSG allocations are finalized. GPD Grants Management Specialists will
contact applicants for any necessary revisions.
• SF-424B, Standard Assurances (Non-Construction), submitted via the forms generated
by ND Grants
o For construction under an award, submit SF-424D, Standard Assurances
(Construction), submitted via the forms generated by ND Grants, in addition to or
instead of SF-424B
• SF-LLL, Disclosure of Lobbying Activities, submitted via the forms generated by ND
Grants
• Indirect Cost Agreement or Proposal, submitted as an attachment in ND Grants if the
budget includes indirect costs and the applicant is required to have an indirect cost rate
agreement or proposal. If the applicant does not have or is not required to have an indirect
cost rate agreement or proposal, please see Section D.13 of this NOFO, “Funding
Restrictions and Allowable Costs,” for further information regarding allowability of
indirect costs and whether alternatives to an indirect cost rate agreement or proposal might
be available or contact the relevant FEMA staff identified in Section G of this NOFO,
“DHS Awarding Agency Contact Information” for further instructions.
Generally, applicants have to submit either the non-construction forms (i.e., SF-424A and SF-
424B) or construction forms (i.e., SF-424C and SF-424D), meaning that applicants that only
have construction work and do not have any non-construction work need only submit the
construction forms (i.e., SF-424C and SF-424D) and not the non-construction forms (i.e., SF-
424A and SF-424B), and vice versa. However, applicants who have both construction and
non-construction work under this program need to submit both the construction and non-
construction forms.
b. Program-Specific Required Forms and Information
I. IJ DEVELOPMENT: SHSP AND UASI
As part of the FY 2022 HSGP application process for SHSP and UASI funds, applicants must
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develop formal IJs that address the proposed investments. Failure to fulfill all of the terms
contained in this section will be considered by DHS/FEMA in its evaluation of the
effectiveness of the IJs submitted to meet the minimum percent spend requirement for the
National Priority Areas. Failure to sufficiently align projects to the National Priority Areas
and meet the minimum percent spend requirement will result in funds being placed on hold
until those issues are addressed.
FY 2022 SHSP and UASI applications must include one (1) IJ and at least one (1) respective
project for each of the four National Priority Areas with a minimum spend requirement (Soft
Targets/Crowded Places, Intelligence and Information Sharing, Countering Domestic Violent
Extremism, and Community Preparedness and Resilience) identified in this NOFO. Each of
these IJs must also meet or exceed the minimum percent spend requirement based on the
applicant’s SHSP and UASI allocation stated in this NOFO. All projects associated with the
minimum spend of a National Priority Area must be submitted in the same IJ. SAAs
may submit complete project-level information at the time of application but are not required
to do so at the time of application. However, any SHSP or UASI application that does not
include an IJ for each National Priority Area that meets the minimum spend requirement will
have that funding placed on hold (up to the National Priority Area minimum percent and up to
30 percent of the total SHSP or UASI allocations) until those IJs and project-level details that
sufficiently address the National Priority Areas are received and approved by DHS/FEMA.
Each IJ must demonstrate how proposed investments:
• Support terrorism preparedness; and
• Support closing capability gaps or sustaining capabilities identified in the community’s
THIRA/SPR process.
Each IJ must explain how the proposed investments will support the applicant’s efforts to:
• Prevent a threatened or an actual act of terrorism;
• Prepare for all hazards and threats, while explaining the nexus to terrorism preparedness;
• Protect citizens, residents, visitors, and assets against the greatest threats and hazards,
relating to acts of terrorism; and/or
• Respond quickly and equitably to save lives, protect property and the environment, and
meet basic human needs in the aftermath of an act of terrorism or other catastrophic
incidents.
If not included in the application, SHSP and UASI recipients must submit complete project-
level information for each SHSP and UASI IJ as part of the Biannual Strategy
Implementation Report (BSIR) due by January 30, 2022. This includes IJs for the National
Priority Areas.
DHS/FEMA will evaluate the effectiveness of the projects submitted in support of the
National Priority Areas, either at the time of application or as part of the December 2022
BSIR. DHS/FEMA will not reduce FY 2022 HSGP awards based on the effectiveness review
but will work with recipients to ensure compliance with the National Priority Area
requirements based on the results of the effectiveness review. Recipients and subrecipients
will not be permitted to expend funding under the National Priority Areas until the
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effectiveness of the proposed projects has been reviewed and confirmed by FEMA.
II. DEVELOPMENT OF INVESTMENTS AND PROJECTS: SHSP AND UASI
• Applicants must propose at least four and may include up to 12 investments.
• Within each investment, applicants must propose at least one project to describe the
activities they plan to implement with SHSP and UASI funds. There is no limit to the
number of projects that may be submitted.
• Required National Priority Area IJs must include the name of the priority in the investment
name for easy identification.
• All requested funding must be associated with specific projects. For each project, several
pieces of information must be provided to submit the project for consideration in the
application, including:
o Project name;
o Project description;
o Subrecipient name, if applicable;
o Recipient type (e.g., state or local);
o Project location (zip code of the primary location of the project);
o Primary core capability the project supports;
o Whether the project activities are shareable and deployable; and
o Which National Priority Area (if any) the project supports.
• Projects should describe how the proposed investment supports closing capability gaps or
sustaining capabilities identified in the THIRA/SPR process.
• FEMA encourages states to use any DHS provided assessments, such as those performed by
DHS’s Protective Security Advisors and Cybersecurity Advisors, when developing their IJs.
III. NATIONAL PRIORITY AREA INVESTMENTS: SHSP AND UASI
States are encouraged to review the Strategic Framework for Countering Terrorism and
Targeted Violence when developing investments.
• Soft Targets/Crowded Places (3 percent)
Soft targets and crowded places are increasingly appealing to terrorists and other violent
extremist actors because of their relative accessibility and the large number of potential
targets. This challenge is complicated by the prevalent use of simple tactics and less
sophisticated attacks. Segments of our society are inherently open to the general public, and
by nature of their purpose do not incorporate strict security measures. Given the increased
emphasis by terrorists and other violent extremist actors to leverage less sophisticated
methods to inflict harm in public areas, it is vital that the public and private sectors
collaborate to enhance security of locations such as transportation centers, parks,
restaurants, shopping centers, special event venues, polling places, and similar facilities.
The malicious use of unmanned aircraft systems poses a threat to the safety and security of
the American people, communities, and institutions. Technologies to detect or mitigate
unmanned aircraft systems are an allowable use under the HSGP in accordance with the
Domestic Counter-Unmanned Aircraft Systems (UAS) National Action Plan. Recipients
should ensure that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, they seek the advice of counsel experienced with both federal
and state criminal, surveillance, and communications laws which may apply to the use of
such technologies.
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Given the increased risk to soft targets and crowded places, at least one investment must be
in support of the state’s and high-risk urban area’s efforts to protect soft targets/crowded
places. Additionally, the proposed investment must meet or exceed the FY 2022 national
priority percentage for soft targets/crowded places and will also be subject to DHS/FEMA’s
evaluation of the effectiveness of the proposed investments. States are also encouraged to
engage DHS’ Protective Security Advisors’ security assessments of soft targets to ensure
that recommendations from those assessments are taken into consideration when allocating
grant funding.
Additional resources and information regarding securing soft targets and crowded places are
available through the Cybersecurity and Infrastructure Security Agency and the National
Institute of Standards and Technology.
• Information and Intelligence Sharing (3 percent)
Effective homeland security operations rely on access to, analysis of, and the timely sharing
of open source, unclassified, and classified information, suspicious activity reports,
tips/leads, and actionable intelligence on indicators and behaviors to accurately identify,
assess, and mitigate a wide array of threats against the United States, including terrorism,
threats to life, targeted violence, and other threats within the DHS mission space.
Accordingly, DHS works diligently to enhance intelligence collection, integration, analysis,
and information sharing capabilities to ensure partners, stakeholders, and senior leaders
receive actionable intelligence and information necessary to inform their decisions and
operations. A critical and statutorily charged mission of DHS is to deliver intelligence and
information to federal, state, local, and tribal governments and private sector partners.
Cooperation and information sharing among state, federal, and local partners across all
areas of the homeland security enterprise, including counterterrorism – including both
international and domestic terrorism, cybersecurity, border security, transnational organized
crime, immigration enforcement, economic security, and other areas, while upholding
privacy, civil rights and civil liberties protections, is critical to homeland security operations
and the prevention of, preparation for, protection against, and response to acts of terrorism,
and other threats to life and criminal acts of targeted violence.
Given the importance of information sharing and collaboration to effective homeland
security solutions, at least one investment must be in support of the state’s and high-risk
urban area’s efforts to enhance information sharing and cooperation with DHS and other
federal agencies. As noted above, this requirement must include at least one dedicated
fusion center project. Additional instructions on development of the fusion center project
can be found below. Applicants must justify persuasively how they will contribute to the
information sharing and collaboration purposes of the investment and a culture of national
preparedness. Additionally, the proposed investment must meet or exceed the FY 2022
national priority percentage for information sharing and will also be subject to
DHS/FEMA’s evaluation of the effectiveness of the proposed investments.
Additional resources and information regarding collaboration and information sharing are
available through the Department’s Office of Intelligence and Analysis.
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• Domestic Violent Extremism (3 percent)
As stated in the October 2020 DHS Homeland Threat Assessment, domestic violent
extremists, including ideologically motivated lone offenders and small groups, present the
most persistent and lethal terrorist threat to the Homeland. These violent extremists
capitalize on social and political tensions, which have resulted in an elevated threat
environment. They utilize social media platforms and other technologies to spread violent
extremist ideologies that encourage violence and influence action within the United States.
The COVID-19 pandemic has further created an environment that may lead to accelerated
mobilization to targeted violence and/or radicalization to domestic terrorism, including
leveraging lawful protests to incite violence, intimidate targets, and promote their violent
extremist ideologies.
Given the rise of domestic violent extremism in recent years, at least one investment must
be in support of the state’s and high-risk urban area’s efforts to combat the rise, influence,
and spread of domestic violent extremism. Additionally, the proposed investment must meet
or exceed the FY 2022 national priority percentage for domestic violent extremism and will
also be subject to DHS/FEMA’s evaluation of the effectiveness of the proposed
investments.
Additional resources and information regarding domestic violent extremism are available
through Center for Prevention Programs and Partnerships | Homeland Security (dhs.gov).
• Cybersecurity (no minimum percent)
Today’s world is more interconnected than ever before, but with increased connectivity
comes increased risk of our adversaries, including terrorists, exploiting cyber vulnerabilities
and weaknesses to disrupt our way of life. While not required, applicants are encouraged to
submit an investment related to their ongoing or near-term high priority cybersecurity
projects. The investment will be subject to DHS/FEMA’s evaluation of the effectiveness of
the proposed investments. Cybersecurity investments must support the security and
functioning of critical infrastructure and core capabilities as they relate to preventing,
preparing for, protecting against, or responding to acts of terrorism. Recipients and
subrecipients of FY 2022 HSGP grant awards will be required to complete the 2022
Nationwide Cybersecurity Review (NCSR), enabling agencies to benchmark and measure
progress of improving their cybersecurity posture. The Chief Information Officer (CIO),
Chief Information Security Officer (CISO) or equivalent for each recipient should complete
the NCSR. If there is no CIO or CISO, the most senior cybersecurity professional should
complete the assessment. The NCSR is available at no cost to the user and takes
approximately 2-3 hours to complete. The 2022 NCSR is estimated to be open from October
2022 – February 2023.
The NCSR is an annual requirement for recipients and subrecipients of HSGP funds.
Additionally, FEMA recognizes that some subawards will not be issued until after the
NCSR has closed. In such cases, such subrecipients will be required to complete the first
available NCSR offered after the subaward has been issued by the pass-through entity.
Although not required by SLTTs that did not receive HSGP funds, all SLTT agencies with
preparedness responsibilities are highly encouraged to participate and complete the NCSR
to evaluate their cybersecurity posture. For detailed information and background on the
NCSR, please see IB 439.
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Additional resources and information regarding cybersecurity are available through the
Cybersecurity and Infrastructure Security Agency and the National Institute of Standards
and Technology.
• Community Preparedness and Resilience (3 percent)
Community organizations are the backbones of American civic life, both during “blue
skies” and in the aftermath of terrorist attacks. Community organizations, such as homeless
shelters, food banks, public libraries, faith-based institutions, and nonprofit medical
providers must have the capabilities to withstand acts of terrorism and provide essential
services, especially to members of underserved communities, in the aftermath of an attack.
In addition, individual citizens and volunteer responders, such as Community Emergency
Response Teams, are often the first on the scene after a terrorist attack. The ability of these
volunteers to provide assistance to their fellow citizens prior to the arrival of professional
first responders is paramount to a community’s resilience. FEMA’s 2021 National
Household Survey recorded an 11% decline in the number of Americans that have taken at
least three preparedness actions to bolster individual and household resilience. In addition,
the COVID-19 pandemic has placed a significant burden on community-based
organizations such as homeless shelters, food banks, public libraries, faith-based
institutions, and nonprofit medical providers to continue to provide key services during and
after disasters, including acts of terrorism. This National Priority Area will bolster
community preparedness and resilience by investing in local, community-driven
capabilities.
Additionally, equity in emergency management requires proactively prioritizing actions that
reinforce cultural competency, accessibility, and inclusion, as well as reflect the historical
context of specific groups of people. To that end, states, territories, and high-risk urban
areas are strongly encouraged to explore how SHSP- and UASI-funded activities can
address the needs of underserved, at-risk communities to help ensure consistent and
systematic, fair, just, and impartial treatment of all individuals before, during, and after a
disaster.
The focus on equity and investing in strategies that meet the needs of underserved
communities will strengthen the whole of community system of emergency management.
Substantial and ongoing prioritization of, and investment in, underserved communities is
essential for the entire system to be effective and efficient. Engaging the whole community
requires all members of the community to be part of the emergency management team,
including representatives of underserved communities, diverse community members, social
and community service groups and institutions, faith-based and disability advocacy groups,
academia, professional associations, the private and nonprofit sectors, and government
agencies that may not traditionally have been directly involved in emergency management.
The whole community includes children; older adults; individuals with disabilities and
others with access and functional needs; those from religious, racial, and ethnically diverse
backgrounds; people with limited English proficiency; and owners of animals including
household pets and service animals.
These factors underpin the requirement that at least one investment must be in support of
the state’s and urban area’s efforts to address community preparedness and resilience.
Additionally, the proposed investment must meet or exceed the FY 2022 national priority
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percentage for community preparedness and resilience and will also be subject to
DHS/FEMA’s evaluation of the effectiveness of the proposed investments.
Additional resources and information regarding community preparedness and resilience are
available through Individuals and Communities | FEMA.gov.
• Election Security (no minimum percent)
In January 2017, DHS designated the infrastructure used to administer the Nation’s
elections as critical infrastructure. This designation recognizes that the United States’
election infrastructure is of such vital importance to the American way of life that its
incapacitation or destruction would have a devastating effect on the country. Securing
election infrastructure and ensuring an election free from foreign interference are national
security priorities. Threats to election systems are constantly evolving, so defending these
systems requires constant vigilance, innovation, and adaptation. As such, while not
required, applicants are encouraged to submit an investment related to their election security
needs.
If submitted, the investment will be subject to DHS/FEMA’s evaluation of the effectiveness
of the proposed investments. Any activities proposed that could be used to suppress
voter registration or turnout will not be approved.
Additional resources and information regarding election security are available through the
Cybersecurity and Infrastructure Security Agency.
IV. DEVELOPMENT OF FUSION CENTER PROJECTS: SHSP AND UASI
Each applicant must identify a fusion center project that will:
• Indicate alignment to a designated Fusion Center; and
• Provide both a brief narrative description and funding itemization for the proposed project
activities that directly support the designated fusion center.
The descriptive narrative and the financial itemization should align improvement or
sustainment requests with fusion center activities as they relate to the Fusion Center
Performance Measures found in the Preparedness Grants Manual.
Sample Fusion Center Funding Itemization
A sample project description and funding itemization are below. For the itemized projects,
clearly identify the anticipated fusion center performance improvement or sustainment as a
result of the proposed funding.
The X Fusion enhancement project will fund:
• Salaries, benefits, and training for X number of Fusion Center intelligence analysts
• Travel costs associated with fusion center analyst training
• This project will directly sustain the Center’s current capabilities and performance
and directly aligns with performance measures 2022.XXX
• We anticipate seeing an improvement in the quality and quantity of analytic
production and responses to requests for information as a direct result of the funding
of this project
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The funding itemization for a fusion center project should include the amount and percent of each
relevant solution area. As an example:
Solution Area and Amount of Proposed
Funding
Percent of Proposed
Funding
Planning: $10,000 2%
Organization: $200,000 48%
Equipment: $200,000 48%
Training: $10,000 2%
Exercises: $0 0%
Total: $420,000 100%
V. COMPLETING IJS IN THE GRANT REPORTING TOOL (GRT): SHSP AND UASI
In the Related Documents section of the Grants.gov posting, applicants can find the IJ template
and instructions for collecting the required information for investments and projects.
Additionally, applicants should utilize the Project Worksheet located in Grants.gov posting to
assemble the information required for each project, which will facilitate the input of that
information into the GRT.
Applicants must ensure the appropriate National Priority Area “Investment Type” (Overview
Tab – Investment Information Section) is selected for the corresponding National Priority Area.
VI. DEVELOPMENT OF CONCEPT OF OPERATIONS FOR OPSG
As part of the FY 2022 OPSG application process, each eligible local unit of government at the
county or federally recognized tribal government level must develop a strategic plan called a
Concept of Operations (CONOP)/Application, which is a formal proposal of action to address a
specific situation and forms the basis for Operations Orders, in coordination with state and
federal law enforcement agencies, to include, but not limited to CBP/USBP. CONOPs that are
developed at the county level should be inclusive of city, county, tribal, and other local law
enforcement agencies that are eligible to participate in OPSG operational activities, and the
CONOP/Application should describe participating agencies in the Executive Summary.
CONOP/Application details should include the names of the agencies, points of contact, and
individual funding requests. All CONOPs/Applications must be developed in collaboration with
the local USBP sector office, the SAA, and the local unit of government. Requests for funding
in CONOPs/Applications must be based on risks and the operational enforcement support
requirements of its corresponding USBP Sector, as well as the national priorities identified
below. USBP Sector offices will forward the CONOPs to USBP Headquarters for vetting and
coordination. Applicants will forward corresponding OPSG Applications to the SAA for
submission to FEMA. USBP Headquarters will reconcile all submitted CONOPs with the
OPSG Applications. FEMA will review and evaluate all CONOPs and OPSG Applications and
funding will be allocated based on the review and selection criteria identified in this NOFO.
OPSG Applicants will be required to clearly articulate and identify how the CONOPs will
address the national priority identified below:
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• Information and Intelligence Sharing and Cooperation
Effective border security operations rely on access to, analysis of, and the timely sharing of
open source, unclassified, and classified information, suspicious activity reports, tips/leads,
and actionable intelligence on indicators and behaviors to accurately identify, assess, and
mitigate a wide array of threats against the United States, including terrorism, threats to life,
targeted violence, and other threats within the DHS mission space. Accordingly, DHS
works diligently to enhance intelligence collection, integration, analysis, and information
sharing capabilities to ensure partners, stakeholders, and senior leaders receive actionable
intelligence and information necessary to inform their decisions and operations. One
critical, statutorily required mission of DHS is to deliver intelligence and information to
federal, state, local, and tribal governments and private sector partners. Cooperation and
information sharing among state, federal, and local partners across all areas of the homeland
security enterprise, including both international and domestic terrorism, cybersecurity,
transnational organized crime, economic security, border security, immigration
enforcement, and other areas, while upholding privacy, civil rights and civil liberties
protections, is critical to homeland security operations and the prevention of, preparation
for, protection against, and responding to acts of terrorism, and other threats to life and
criminal acts of targeted violence.
Given the importance of information sharing and collaboration to effective homeland
security solutions, the CONOP must support the recipient’s efforts to enhance information
sharing and cooperation with DHS and other federal agencies. Applicants must justify
persuasively how they will contribute to the information sharing and collaboration purposes
of the OPSG program and a culture of national preparedness.
Additional resources and information regarding collaboration and information sharing are
available through the Department’s Office of Intelligence and Analysis.
VII. DETAILED Budget
Applicants must provide budget summary worksheets for all funds requested at the time of
application. The budget summary worksheets must be complete, reasonable, and cost-effective
in relation to the proposed project and should provide the basis of computation of all project-
related costs (including management and administrative costs) and any appropriate narrative.
FEMA must be able to thoroughly evaluate the projects being submitted based on the
information provided. FEMA must be able to determine how much funding is being passed
through to subrecipients for each sub-program (UASI, SHSP, OPSG). Consequently, applicants
must provide an appropriate level of detail within the budget summary worksheets to clarify
what will be purchased and spent. Sample budget summary worksheets are available on the
grants.gov posting for the HSGP in the Related Documents tab and may be used as a guide to
assist applicants in the preparation of budgets and budget narratives.
11. Other Submission Requirements
Fusion Center Investments
Of the proposed SHSP- and UASI-funded investments, one single project must be in support of a
designated fusion center. Recipients must coordinate with the fusion center when developing a
fusion center project prior to submission. See additional information on how to develop the
fusion center projects below and in the Preparedness Grants Manual.
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Emergency Communications Investments
All emergency communications investments must describe how such activities align with needs
identified in their Statewide Communication Interoperability Plan (SCIP). Recipients must
coordinate with their Statewide Interoperability Coordinator (SWIC) and/or Statewide
Interoperability Governing Body (SIGB) when developing an emergency communications
investment prior to submission to ensure the project supports the statewide strategy to improve
emergency communications and is compatible and interoperable with surrounding systems.
Effective project alignment will require advance coordination with the SWIC and consultation
with governing bodies such as the SIGB or Statewide Interoperability Executive Committee
(SIEC), as they serve as the primary steering group for the statewide interoperability strategy.
Additionally, recipients should consult subject matter experts serving on governance bodies,
such as broadband experts, chief information officers, representatives from utilities, or legal and
financial experts, when developing proposals. The investment name must include the words
“emergency communications” to easily identify any emergency communications investments.
12. Intergovernmental Review
An intergovernmental review may be required. Applicants must contact their state’s Single
Point of Contact (SPOC) to comply with the state’s process under Executive Order 12372 (See
https://www.archives.gov/federal-register/codification/executive-order/12372.html;
https://www.whitehouse.gov/wp-content/uploads/2020/04/SPOC-4-13-20.pdf ).
13. Funding Restrictions and Allowable Costs
All costs charged to awards covered by this NOFO must comply with the Uniform
Administrative Requirements, Cost Principles, and Audit Requirements at 2 C.F.R. Part 200,
unless otherwise indicated in the NOFO, the terms and conditions of the award, or the
Preparedness Grants Manual. This includes, among other requirements, that costs must be
incurred, and products and services must be delivered, within the period of performance of the
award. See 2 C.F.R. § 200.403(h) (referring to budget periods, which for FEMA awards under
most programs, including this program, is the same as the period of performance).
Federal funds made available through this award may be used for the purpose set forth in this
NOFO, the Preparedness Grants Manual, and the terms and conditions of the award and must be
consistent with the statutory authority for the award. Award funds may not be used for matching
funds for any other federal awards, lobbying, or intervention in federal regulatory or
adjudicatory proceedings. In addition, federal funds may not be used to sue the Federal
Government or any other government entity. See the Preparedness Grants Manual for more
information on funding restrictions and allowable costs.
a. Prohibitions on Expending FEMA Award Funds for Covered Telecommunications
Equipment or Services
Recipients and subrecipients of FEMA federal financial assistance are subject to the
prohibitions described in section 889 of the John S. McCain National Defense Authorization Act
for Fiscal Year 2019 (FY 2019 NDAA), Pub. L. No. 115-232 (2018) and 2 C.F.R. §§ 200.216,
200.327, 200.471, and Appendix II to 2 C.F.R. Part 200. Beginning August 13, 2020, the statute
– as it applies to FEMA recipients, subrecipients, and their contractors and subcontractors –
prohibits obligating or expending federal award funds on certain telecommunications and video
surveillance products and contracting with certain entities for national security reasons.
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Guidance is available at Prohibitions on Expending FEMA Award Funds for Covered
Telecommunications Equipment or Services (Interim) FEMA Policy #405-143-1, or
superseding document.
Additional guidance is available Contract Provisions Guide: Navigating Appendix II to Part
200 - Contract Provisions for Non-Federal Entity Contracts Under Federal Awards
(fema.gov).
Effective August 13, 2020, FEMA recipients and subrecipients may not use any FEMA funds
under open or new awards to:
(1) Procure or obtain any equipment, system, or service that uses covered
telecommunications equipment or services as a substantial or essential component of
any system, or as critical technology of any system;
(2) Enter into, extend, or renew a contract to procure or obtain any equipment, system, or
service that uses covered telecommunications equipment or services as a substantial or
essential component of any system, or as critical technology of any system; or
(3) Enter into, extend, or renew contracts with entities that use covered
telecommunications equipment or services as a substantial or essential component of
any system, or as critical technology as part of any system.
I. REPLACEMENT EQUIPMENT AND SERVICES
FEMA grant funding may be permitted to procure replacement equipment and services
impacted by this prohibition, provided the costs are otherwise consistent with the requirements
of the NOFO and the Preparedness Grants Manual.
II. DEFINITIONS
Per section 889(f)(2)-(3) of the FY 2019 NDAA and 2 C.F.R. § 200.216, covered
telecommunications equipment or services means:
i. Telecommunications equipment produced by Huawei Technologies Company or
ZTE Corporation, (or any subsidiary or affiliate of such entities);
ii. For the purpose of public safety, security of Government facilities, physical
security surveillance of critical infrastructure, and other national security
purposes, video surveillance and telecommunications equipment produced by
Hytera Communications Corporation, Hangzhou Hikvision Digital Technology
Company, or Dahua Technology Company (or any subsidiary or affiliate of such
entities);
iii. Telecommunications or video surveillance services provided by such entities or
using such equipment; or
iv. Telecommunications or video surveillance equipment or services produced or
provided by an entity that the Secretary of Defense, in consultation with the
Director of National Intelligence or the Director of the Federal Bureau of
Investigation, reasonably believes to be an entity owned or controlled by, or
otherwise connected to, the People’s Republic of China.
Examples of the types of products covered by this prohibition include phones, internet, video
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surveillance, and cloud servers when produced, provided, or used by the entities listed in the
definition of “covered telecommunications equipment or services.” See 2 C.F.R. § 200.471.
b. Pre-Award Costs
Pre-award costs are allowable only with the prior written approval of DHS/FEMA and as
included in the award agreement. To request pre-award costs, a written request must be
included with the application, signed by the AOR of the entity. The letter must outline what the
pre-award costs are for, including a detailed budget break-out of pre-award costs from the post-
award costs, and a justification for approval.
c. Management and Administration (M&A) Costs
M&A costs are allowed. Recipients may use a maximum of up to 5% of HSGP funds awarded
for their M&A, and any funds retained are to be used solely for M&A purposes associated with
the HSGP award. Subrecipients may also use a maximum of up to 5% of the funding passed
through by the state solely for M&A purposes associated with the HSGP award. M&A
activities are those directly relating to the management and administration of HSGP funds, such
as financial management and monitoring. M&A expenses must be based on actual expenses or
known contractual costs. M&A requests that are simple percentages of the award, without
supporting justification, will not be allowed or considered for reimbursement. A maximum of
up to five percent of HSGP funds awarded may be retained by the state, and any funds retained
are to be used solely for M&A purposes associated with the HSGP award. Subrecipients may
also retain a maximum of up to five percent of the funding passed through by the state solely
for M&A purposes associated with the HSGP award.
M&A costs are not operational costs. They are the necessary costs incurred in direct support of
the grant or as a consequence of the grant and should be allocated across the entire lifecycle of
the grant. Examples include preparing and submitting required programmatic and financial
reports, establishing and/or maintaining equipment inventory, documenting operational and
equipment expenditures for financial accounting purposes, responding to official informational
requests from state and federal oversight authorities, including completing the Civil Rights
Evaluation Tool as required by DHS, and grant performance measurement or evaluation
activities. Please see the Preparedness Grants Manual for additional information on direct costs.
Recipients or subrecipients may apply or credit M&A funding toward the recipient’s
requirement to allocate funding toward the five National Priority Areas. For example, if a
recipient spends $5,000 to manage or administer its funding dedicated toward its soft
targets/crowded places investment, the recipient may credit that funding toward its requirement
to allocate at least 3 percent of its award to the enhancing the protection of soft targets and
crowded places National Priority Area.
A state’s HSGP funds for M&A calculation purposes includes the total of its SHSP, UASI, and
OPSG awards. While the SAA may retain up to five percent of this total for M&A, the state
must still ensure that all subrecipient award amounts meet the mandatory minimum pass-
through requirements that are applicable to each HSGP program. To meet this requirement, the
percentage of SHSP and UASI funds passed through to local or tribal jurisdictions must be
based on the state’s total HSGP award prior to withholding any M&A.
In retaining these funds, states may retain a maximum of 2.5 percent of the OPSG allocation,
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which must be withheld from the pass-through to each subrecipient county or tribe in an equal
percentage. The SAA may also retain additional funding from its SHSP award to manage and
administer the OPSG award, but that additional amount is also capped at an amount equal to 2.5
percent of the OPSG award. Examples applying this principle:
SAA 1:
Total award: $6,000,000
SHSP: $1,000,000 OPSG: $2,500,000 UASI: $2,500,000
M&A Maximum: $300,000 (5 percent of $6,000,000)
Maximum M&A for SHSP = $50,000
Maximum M&A for OPSG = $125,000. Of that amount, $62,500 (2.5 percent) may be
retained from the OPSG allocation, and the other $62,500 would come from the SHSP
allocation. Any amount used to manage and administer OPSG that is charged to SHSP
may be above and beyond the $50,000 available to manage the SHSP allocation.
Maximum M&A for UASI = $125,000
SAA 2:
Total award: $4,500,000
SHSP: $3,500,000 OPSG: $1,000,000
M&A Maximum: $225,000 (5 percent of $4,500,000)
Maximum M&A for SHSP = $175,000
Maximum M&A for OPSG = $50,000. Of that amount, $25,000 (2.5 percent) may be
retained from the OPSG allocation, and the other $25,000 would come from the SHSP
allocation. Any amount used to manage and administer OPSG that is charged to SHSP
may be above and beyond the $175,000 available to manage the SHSP allocation.
HSGP recipients are also reminded that any M&A charged to a recipient’s or subrecipient’s
UASI funding must be directly allocable to administration of the UASI grant program and
cannot be used to cover M&A costs that are directly allocable to SHSP or OPSG funding.
Similarly, any M&A charged to a recipient’s or subrecipient’s SHSP or OPSG funding cannot
be used to cover M&A costs directly allocable to UASI funding.
Please note, IB 365: Management and Administration Costs in the Homeland Security Grant
Program and DHS/FEMA Policy 207-087-1 do not apply to awards made in FY 2022 under
this NOFO. Please also reference IB 416 for additional clarification on OPSG M&A, but to the
extent that there is any conflict between IB 416 and this NOFO, the requirements of this NOFO
will apply to FY 2022 awards made under this NOFO.
d. Indirect Facilities & Administrative (F&A) Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2
C.F.R. § 200.414. Applicants with a current negotiated indirect cost rate agreement that desire
to charge indirect costs to an award must provide a copy of their negotiated indirect cost rate
agreement at the time of application. Not all applicants are required to have a current
negotiated indirect cost rate agreement. Applicants that are not required by 2 C.F.R. Part 200 to
have a negotiated indirect cost rate agreement but are required by 2 C.F.R. Part 200 to develop
an indirect cost rate proposal must provide a copy of their proposal at the time of application.
Applicants who do not have a current negotiated indirect cost rate agreement (including a
provisional rate) and wish to charge the de minimis rate must reach out to the FEMA Grants
Management Specialist for further instructions. Applicants who wish to use a cost allocation
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plan in lieu of an indirect cost rate must also reach out to the FEMA Grants Management
Specialist for further instructions. Post-award requests to charge indirect costs will be
considered on a case-by-case basis and based upon the submission of an agreement or proposal
as discussed above or based upon on the de minimis rate or cost allocation plan, as applicable.
e. Funds Transfer Restriction
The recipient is prohibited from transferring funds between programs (includes SHSP, UASI,
and OPSG). Recipients can submit an investment/project where funds come from multiple
funding sources (e.g., SHSP and UASI), however, recipients are not allowed to divert funding
from one program to another due to the risk-based funding allocations, which were made at the
discretion of DHS/FEMA.
f. Other Direct Costs
I. PLANNING
Planning costs are allowed under this program. Please see the Preparedness Grants Manual for
more information.
II. ORGANIZATION
Organization costs are allowed under this program. Please see the Preparedness Grants Manual
for more information.
III. EQUIPMENT
Equipment costs are allowed under this program. Please see the Preparedness Grants Manual
for more information.
• General Purpose Equipment
HSGP allows expenditures on general purpose equipment if it aligns to and supports one or
more core capabilities identified in the Goal and has a nexus to terrorism preparedness.
General purpose equipment, like all equipment funded under the HSGP, must be sharable
through the EMAC 3 and allowable under 6 U.S.C. § 609, and any other applicable provision of
the Homeland Security Act of 2002, as amended. Examples of such general-purpose equipment
may include:
o Law enforcement vehicles;
o Emergency medical services (EMS) equipment and vehicles;
o Fire service equipment and vehicles, to include hose, pump accessories, and foam
concentrate for specialized CBRNE response;
o Interoperability of data systems, such as computer aided dispatch (CAD) and record
management systems (RMS); and
o Office equipment for staff 4 engaged in homeland security program activity.
• Controlled Equipment
For decades, the federal government has provided equipment to state, local, and tribal law
enforcement agencies (LEAs) through federal grants. Some federal grant programs have
3 Except for American Samoa and the Commonwealth of the Northern Mariana Islands, which are not required to
belong to EMAC at this time.
4 This applies to all homeland security personnel and is not limited to M&A staff, and costs are to be captured outside
the cap on M&A costs
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assisted LEAs as they carry out their critical missions to keep the American people safe. The
equipment acquired by LEAs through these programs includes administrative equipment, such
as office furniture and computers. Some federal grant programs also may include military and
military-styled equipment, firearms, and tactical vehicles provided by the federal government,
including property covered under 22 C.F.R. Part 121 and 15 C.F.R. Part 774 (collectively,
"controlled equipment").
However, not all equipment that is considered controlled equipment is allowable under the
HSGP. As discussed below, certain equipment is “prohibited” and is not allowable under
HSGP. For some controlled equipment that is allowable under the HSGP, additional
documentation, justifications, reviews, and approvals are required, including but not limited to
proof of policies and procedures to safeguard individuals’ privacy, civil rights, and civil
liberties.
DHS/FEMA will continue to collaborate with federal agency partners to ensure that there is a
consistent and reasonable approach to the restrictions placed on controlled equipment
expenditures while continuing to support these investments when there is a justifiable need.
Further, DHS/FEMA will continue to maintain an awareness of the evolving policy
developments related to controlled equipment expenditures and keep grant recipients up to
date on future developments.
Grant funds under this program may not be used for the purchase of equipment not approved
by DHS/FEMA. The purchase of tracked armored vehicles, camouflage uniforms, weapons
and weapons accessories, including ammunition, is not allowed with HSGP funds. Grant funds
under this program must also comply with IB 426 and may not be used for the purchase of the
following equipment: 1) firearms; 2) ammunition; 3) grenade launchers; 4) bayonets; or 5)
weaponized aircraft, vessels, or vehicles of any kind with weapons installed.
IV. TRAINING
Training costs are allowed under this program. Please see the Preparedness Grants Manual for
more information.
V. EXERCISES
Exercise costs are allowed under this program. Please see the Preparedness Grants Manual for
more information.
VI. PERSONNEL
Personnel hiring, overtime, and backfill expenses are permitted under this grant to perform
allowable HSGP planning, organization, training, exercise, and equipment activities. Under
OPSG, overtime costs are allowable only in so far as they meet the intent of the program. All
recipients and subrecipients of HSGP funds, including SHSP, UASI, and OPSG allocations,
may not use more than 50 percent of their awards to pay for personnel activities unless a
waiver is approved by FEMA. For more information on the 50 percent personnel cap, please
see FEMA IB 421b, Clarification on the Personnel Reimbursement for Intelligence
Cooperation and Enhancement of Homeland Security Act of 2008 (Public Law 110-412) – the
PRICE Act. Please see the Preparedness Grants Manual for more information.
VII. OPERATIONAL OVERTIME
Operational overtime costs are allowed under this program. Prior to use of funds for
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operational overtime, recipients must receive approval from DHS/FEMA. Operational
overtime costs are also subject to the 50 percent personnel cap. Please see the Preparedness
Grants Manual for more information.
VIII. TRAVEL
Domestic travel costs are allowed under this program, as provided for in this NOFO and in the
Preparedness Grants Manual. International travel is not an allowable cost under this program
unless approved in advance by DHS/FEMA.
IX. CONSTRUCTION AND RENOVATION
Construction and renovation costs to achieve capability targets related to preventing, preparing
for, protecting against, or responding to acts of terrorism are allowed under this program. For
construction and renovation costs to be allowed, they must be specifically approved by
DHS/FEMA in writing prior to the use of any program funds. Applicants must use the
Environmental Planning and Historical Preservation (EHP) approval process. Limits on the
total amount of grant funding that may be used for construction or renovation may apply.
Additionally, recipients are required to submit SF-424C and SF-424D. Please see the
Preparedness Grants Manual for more information.
X. MAINTENANCE AND SUSTAINMENT
Maintenance- and sustainment-related costs, such as maintenance contracts, warranties, repair
or replacement costs, upgrades, and user fees, are allowable. Please see the Preparedness
Grants Manual for more information.
XI. CRITICAL EMERGENCY SUPPLIES
Critical emergency supplies are allowed under this program. Please see the Preparedness
Grants Manual for more information.
XII. SECURE IDENTIFICATION
Secure Identification costs are allowed under this program. Please see the Preparedness Grants
Manual for more information.
Allowable Cost Matrix
The following matrix provides allowable cost activities that fall under each of the cost categories
noted above. Recipients and subrecipients must follow all applicable requirements in 2 C.F.R. Part
200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards. HSGP funds may be used to cover the costs for evaluating the impact of these grants on
the state or urban area’s core capabilities and capability gaps. This list is not exhaustive, therefore,
if there are any questions regarding allowable costs, please contact the appropriate HQ FEMA
Preparedness Officer. For additional information on allowable costs, see the Preparedness Grants
Manual.
Allowable Program Activities SHSP UASI OPSG
Allowable Planning Costs
Developing hazard/threat-specific annexes Y Y N
Developing and implementing homeland security support programs and adopting
ongoing DHS/FEMA national initiatives Y Y N
Developing related terrorism and other catastrophic event prevention activities Y Y N
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Allowable Program Activities SHSP UASI OPSG
Developing and enhancing plans and protocols Y Y N
Developing or conducting assessments Y Y N
Hiring of full- or part-time staff or contract/consultants to assist with planning,
engagement, and volunteer management activities Y Y N
Materials required to conduct planning, engagement, and volunteer management
activities Y Y N
Travel/per diem related to planning, engagement, and volunteer management activities Y Y Y
Overtime and backfill costs (in accordance with operational Cost Guidance) Y Y Y
Issuance of Western Hemisphere Travel Initiative-compliant Tribal identification cards Y N N
Activities to achieve planning inclusive of people with disabilities and others with access
and functional needs and limited English proficiency. Y Y N
Coordination with Citizen Corps Councils for public information/education and
development of volunteer programs Y Y N
Coordination and material support to Citizen Corps Councils and local firehouses for
the establishment, training and maintenance of CERTs Y Y N
Update governance structures and processes and plans for emergency communications Y Y N
Development, and review and revision of continuity of operations plans Y Y N
Development, and review and revision of the THIRA/SPR continuity of operations
plans Y Y N
Developing or conducting equity assessments to address planning and preparedness
disparities for historically underserved communities Y Y N
Allowable Organizational Activities
Note: Personnel hiring, overtime, and backfill expenses are permitted under this grant only to the extent that such
expenses are for the allowable activities within the scope of the grant.
Program management Y Y N
Development of whole community partnerships Y Y N
Structures and mechanisms for information sharing between the public and private
sector Y Y N
Implementing models, programs, and workforce enhancement initiatives Y Y N
Tools, resources, and activities that facilitate shared situational awareness between the
public and private sectors Y Y N
Operational support Y Y N
Utilization of standardized resource management concepts Y Y N
Responding to an increase in the threat level under the National Terrorism Advisory
System (NTAS), or needs in resulting from a National Special Security Event Y Y N
Reimbursement for select operational expenses associated with increased security
measures at critical infrastructure sites incurred (up to 50 percent of the allocation) Y Y Y
Overtime for information, investigative, and intelligence sharing activities (up to 50
percent of the allocation) Y Y Y
Hiring of new staff positions/contractors/consultants for participation in
information/intelligence analysis and sharing groups or fusion center activities (up to 50
percent of the allocation).
Y Y Y
Hiring or maintaining staff positions/contractors/consultants at SLTT levels to deliver
community preparedness training, resources and material to schools, community-based
organizations, faith-based institutions and local businesses.
Y Y N
Hiring or maintaining staff positions/contractors/consultants to create, support and
maintain CERT or Teen CERT Y Y N
Cost of migrating online services to the “.gov” domain Y Y N
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Allowable Program Activities SHSP UASI OPSG
Allowable Equipment Categories
Personal Protective Equipment Y Y Y
Allowable Equipment Categories
Explosive Device Mitigation and Remediation Equipment Y Y N
CBRNE Operational Search and Rescue Equipment Y Y N
Information Technology Y Y Y
Cybersecurity Enhancement Equipment Y Y N
Interoperable Communications Equipment Y Y Y
Detection Y Y Y
Decontamination Y Y N
Medical countermeasures Y Y Y
Power (e.g., generators, batteries, power cells) Y Y Y
CBRNE Reference Materials Y Y N
CBRNE Incident Response Vehicles Y Y N
Terrorism Incident Prevention Equipment Y Y Y
Physical Security Enhancement Equipment Y Y Y
Inspection and Screening Systems Y Y Y
Animal Care and Foreign Animal Disease Y Y N
CBRNE Prevention and Response Watercraft Y Y N
CBRNE Prevention and Response Unmanned Aircraft Y Y N
CBRNE Aviation Equipment Y Y N
CBRNE Logistical Support Equipment Y Y N
Intervention Equipment (e.g., tactical entry, crime scene processing) Y Y Y
Critical emergency supplies Y Y N
Vehicle acquisition, lease, and rental N N Y
Other Authorized Equipment Y Y Y
Allowable Training Costs
Overtime and backfill for emergency preparedness and response personnel
attending DHS/FEMA-sponsored and approved training classes Y Y N
Overtime and backfill expenses for part-time and volunteer emergency response
personnel participating in DHS/FEMA training Y Y N
Training workshops and conferences Y Y Y
Activities to achieve training inclusive of people with disabilities and others with
access and functional needs and limited English proficiency Y Y N
Full- or part-time staff or contractors/consultants Y Y Y
Travel Y Y Y
Supplies Y Y N
Instructor certification/re-certification Y Y N
Coordination with Citizen Corps Councils and CERT in conducting training exercises Y Y N
Preparedness training for community preparedness initiatives and programs Y Y N
Interoperable communications training Y Y N
Activities to achieve planning inclusive of people with limited English proficiency Y Y N
Immigration enforcement training Y Y Y
Allowable Exercise Related Costs
Design, Develop, Conduct, and Evaluate an Exercise Y Y N
Full- or part-time staff or contractors/consultants Y Y N
Overtime and backfill costs, including expenses for part-time and volunteer emergency
response personnel participating in DHS/FEMA exercises Y Y N
Implementation of HSEEP Y Y N
Activities to achieve exercises inclusive of people with disabilities and others with
access and functional needs Y Y N
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Allowable Program Activities SHSP UASI OPSG
Travel Y Y N
Supplies Y Y N
Interoperable communications exercises Y Y N
Allowable Exercise Related Costs
Activities to achieve planning inclusive of people with limited English proficiency Y Y N
Allowable M&A Costs
Hiring of full- or part-time staff or contractors/consultants to assist with the
management of the respective grant program, application requirements, and
compliance with reporting and data collection requirements
Y Y Y
Development of operating plans for information collection and processing necessary to
respond to DHS/FEMA data calls Y Y Y
Overtime and backfill costs Y Y Y
Travel Y Y Y
Meeting related expenses Y Y Y
Authorized office equipment Y Y Y
Recurring expenses such as those associated with cell phones and faxes during the
period of performance of the grant program Y Y N
Leasing or renting of space for newly hired personnel during the period of performance
of the grant program Y Y N
Completing the Civil Rights Evaluation Tool Y Y Y
Conducting activities related to evaluating project effectiveness for HSGP-funded
projects Y Y Y
LETPA Costs
Integration and interoperability of systems and data, such as CAD and RMS, to
facilitate the collection, Y Y N
Maturation, enhancement, and sustainment of designated state and major Urban Area
fusion centers, including information sharing and analysis, threat recognition, terrorist
interdiction, and intelligence analyst training and salaries (subject to certain conditions)
Y Y N
Regional counterterrorism training programs for small, medium, and large jurisdictions
to exchange information and discuss the current threat environment, lessons learned,
and best practices to help prevent, protect against, and mitigate acts of terrorism
Y Y N
Coordination of regional full-scale training exercises (federal, state, and local law
enforcement participation) focused on terrorism-related events Y Y N
Law enforcement Chemical, Biological, Radiological, Nuclear, and high yield
Explosives detection and response capabilities, such as bomb detection/disposal
capability development, sustainment, or enhancement, including canine teams, robotics
platforms, and x-ray technology
Y Y N
Coordination between fusion centers and other operational analytic, and investigative
efforts Y Y N
Implementation, maintenance, and sustainment of the Nationwide Suspicious Activity
Reporting Initiative Y Y N
Implementation of the "If You See Something, Say Something®" campaign Y Y N
Increase physical security, through law enforcement personnel and other protective
measures, by implementing preventive and protective measures at critical infrastructure
locations
Y Y N
E. Application Review Information
1. Application Evaluation Criteria
a. Programmatic Criteria
I. RISK METHODOLOGY
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The risk methodology determines the relative risk of terrorism faced by a given area
considering the potential risk of terrorism to people, critical infrastructure, and economic
security. The analysis includes, but is not limited to, threats from violent domestic extremists,
international terrorist groups, and individuals inspired by terrorists abroad. See the
Preparedness Grants Manual for additional information on the risk methodology.
NOTE: The THIRA/SPR process is separate from the risk methodology and its results do not
affect grant allocations.
The Risk Methodology is used to inform allocations under HSGP. For more information on the
SHSP, UASI, and OPSG allocation processes, please see Section B.1 of this NOFO,
“Available Funding for the NOFO.”
II. APPLICATION EVALUATION CRITERIA
FEMA will evaluate the FY 2022 HSGP applications for completeness, adherence to
programmatic guidelines, and anticipated effectiveness of the proposed investments. FEMA’s
review will include verification that each IJ and project:
• Aligns with at least one core capability identified in the Goal;
• Demonstrates how investments support closing capability gaps or sustaining capabilities
identified in the THIRA/SPR process; and
• Supports a NIMS-typed resource and whether those assets are deployable/shareable to
support emergency or disaster operations per existing EMAC agreements.
In addition to the above, FEMA will evaluate whether proposed projects are: 1) both feasible
and effective at reducing the risks for which the project was designed; and 2) able to be fully
completed within the three-year period of performance. FEMA will use the information
provided in the application and after the submission of the first BSIR to determine the
feasibility and effectiveness of a grant project. To that end, IJs should include:
• An explanation of how the proposed project(s) will achieve objectives as identified in
the SPR, including expected long-term impact where applicable, and which core
capability gap(s) it helps to close and how;
• A summary of the status of planning and design efforts accomplished to date (e.g.,
included in a capital improvement plan); and
• A project schedule with clear milestones.
Recipients are expected to conform, as applicable, with accepted engineering practices,
established codes, standards, modeling techniques, and best practices, and participate in the
development of case studies demonstrating the effective use of grant funds, as requested.
FEMA will also review any submitted National Priority Area-aligned IJs and projects to
ensure they meet the minimum spend requirements. Additional information on how the
National Priority Area IJs and projects will be reviewed for effectiveness is included in the
Review and Selection Process section below.
b. Financial Integrity Criteria
Prior to making a federal award, FEMA is required by 31 U.S.C. § 3354, as enacted by the
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Payment Integrity Information Act of 2019, Pub. L. No. 116-117 (2020); 41 U.S.C. § 2313;
and 2 C.F.R. § 200.206 to review information available through any Office of Management
and Budget (OMB)-designated repositories of governmentwide eligibility qualification or
financial integrity information, including whether the applicant is suspended or debarred.
FEMA may also pose additional questions to the applicant to aid in conducting the pre-award
risk review. Therefore, application evaluation criteria may include the following risk-based
considerations of the applicant:
i.Financial stability.
ii. Quality of management systems and ability to meet management standards.
iii. History of performance in managing federal award.
iv. Reports and findings from audits.
v.Ability to effectively implement statutory, regulatory, or other requirements.
c.Supplemental Financial Integrity Criteria and Review
Prior to making a federal award where the anticipated total federal share will be greater than
the simplified acquisition threshold, currently $250,000:
i.FEMA is required to review and consider any information about the applicant,
including information on the applicant’s immediate and highest-level owner,
subsidiaries, and predecessors, if applicable, that is in the designated integrity and
performance system accessible through the System for Award Management (SAM),
which is currently the Federal Awardee Performance and Integrity Information
System (FAPIIS).
ii. An applicant, at its option, may review information in FAPIIS and comment on any
information about itself that a federal awarding agency previously entered.
iii. FEMA will consider any comments by the applicant, in addition to the other
information in FAPIIS, in making a judgment about the applicant’s integrity, business
ethics, and record of performance under federal awards when completing the review
of risk posed by applicants as described in 2 C.F.R. § 200.206.
2.Review and Selection Process
a.SHSP and UASI
All proposed investments will undergo a federal review by DHS/FEMA to verify compliance
with all administrative and eligibility criteria identified in the NOFO. The federal review will
be conducted by FEMA HQ Preparedness Officers. FEMA HQ Preparedness Officers will use
a checklist to verify compliance with all administrative and eligibility criteria identified in the
NOFO. Recipients must be able to demonstrate how investments support closing capability
gaps or sustaining capabilities identified in the THIRA/SPR process. IJs will be reviewed at
both the investment and project level.
Emergency communications investments will be jointly reviewed by FEMA and the DHS
Emergency Communications Division (ECD) to verify compliance with SAFECOM guidance.
FEMA and ECD will coordinate directly with the recipient on any compliance concerns and
will provide technical assistance as necessary to help ensure full compliance.
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Additional Effectiveness Evaluation Criteria for the National Priority Areas
FEMA will evaluate the FY 2022 HSGP IJs and projects submitted in support of the National
Priority Areas for anticipated effectiveness. FEMA’s review will include verification that each
IJ or project meets the National Priority Area required spend percentages.
Cybersecurity investments will be reviewed by DHS/FEMA, CISA, and other DHS
components as appropriate, for compliance with purposes and requirements of the priority
investment area. Proposed investments will be reviewed for effectiveness using the criteria set
forth in this NOFO.
Soft Targets/Crowded Places investments will be reviewed by DHS/FEMA, CISA, and other
DHS components as appropriate, for compliance with purposes and requirements of the
priority investment area. Proposed investments will be reviewed for effectiveness using the
criteria set forth in this NOFO.
Information Sharing and Cooperation Investments will be reviewed by DHS/FEMA, DHS
Office of Intelligence and Analysis, and other DHS components as appropriate, for compliance
with purposes and requirements of the priority investment area. Proposed investments will be
reviewed for effectiveness using the criteria set forth in this NOFO.
For additional information on Fusion Center requirements, please see the Preparedness Grants
Manual.
Domestic violent extremism investments will be reviewed by DHS/FEMA, DHS Office of
Intelligence and Analysis, DHS Center for Prevention Programs and Partnerships, and other
DHS components as appropriate, for compliance with purposes and requirements of the
priority investment area. Proposed investments will be reviewed for effectiveness using the
scoring criteria set forth in this NOFO.
Community preparedness and resilience investments will be reviewed by DHS/FEMA and
other DHS components as appropriate, for compliance with purposes and requirements of the
priority investment area. Proposed investments will be reviewed for effectiveness using the
scoring criteria set forth in this NOFO.
Election security investments will be reviewed by DHS/FEMA, CISA, and other DHS
components as appropriate, for compliance with purposes and requirements of the priority
investment area. Proposed investments will be reviewed for effectiveness using the scoring
criteria set forth in this NOFO.
FEMA will determine whether the proposed approach is clear, logical, and reasonable to
address the priority areas of interest and contribute to a culture of national preparedness. This
includes factors such as the objectives and strategies proposed to address the priority area, how
the objectives and strategies overcome legal, political, or practical obstacles to reduce overall
risk, the process and criteria to select additional relevant projects, and the approach to monitor
awards to satisfy the funding percentage allocations.
For applicants that elect to submit IJs and project-level details for the National Priority Areas
at the time of application, effectiveness will be evaluated prior to award. If the projects are
found to not sufficiently align with the National Priority Area(s), applicants may have funds
placed on hold (up to 30 percent) until the projects are revised to satisfactorily address the
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National Priority Areas.
For applicants that elect to submit IJs and project-level details for the National Priority Areas
as part of the December 2022 BSIR, they will have funds placed on hold in the amount of 30
percent. The hold will be released only after their December 2022 BSIR submission has been
reviewed, and projects related to the National Priority Areas deemed in alignment by
DHS/FEMA.
SAAs are still required to meet pass-through requirements even if funds are on hold
related to the National Priority Areas.
To that end, IJs should include:
• How the proposed investment addresses the National Priority Area;
• An explanation of how the proposed projects were selected and will achieve objectives
and strategies to build or sustain the core capability gaps identified in the SPR,
including expected long-term impact where applicable;
• A summary of the collaboration efforts to prevent, prepare for, protect against, and
respond to acts of terrorism as well as anticipated outcomes of the project.
For FY 2022 SHSP and UASI investments and projects related to the National Priority Areas,
effectiveness will be evaluated based on the following five factors:
• Investment Strategy (40%): Proposals will be evaluated based on the quality and extent
to which applicants describe an effective strategy that demonstrates that proposed
projects support the program objective of preventing, preparing for, protecting against,
and responding to acts of terrorism, to meet its target capabilities, and otherwise reduce
the overall risk to the high-risk urban area, the state, or the Nation.
• Budget (20%): Proposals will be evaluated based on the extent to which applicants
describe a budget plan for each investment demonstrating how the applicant will
maximize cost effectiveness of grant expenditures.
• Impact/Outcomes (40%): Proposals will be evaluated on how this investment helps the
jurisdiction close capability gaps identified in its SPR and addresses the relevant
National Priority Area outlined in this NOFO. Further, proposals will be evaluated on
their identification and estimated improvement of core capability(ies), the associated
standardized target(s) that align with their proposed investment, and the ways in which
the applicant will measure and/or evaluate improvement.
• Past Performance (additional consideration): Proposals will be evaluated based on the
applicants demonstrated capability to execute the proposed investments. In evaluating
applicants under this factor FEMA will consider the information provided by the
applicant and may also consider relevant information from other sources.
b. OPSG
Applications will be reviewed by the SAA and USBP Sector Headquarters for completeness
and adherence to programmatic guidelines and evaluated for anticipated feasibility, need, and
impact of the Operations Orders. For more information on Operations Orders and other
requirements of OPSG, see the Preparedness Grants Manual.
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DHS/FEMA will verify compliance with all administrative and eligibility criteria identified in
the NOFO and required submission of Operations Orders and Inventory of Operations Orders
by the established due dates. DHS/FEMA and USBP will use the results of both the risk
analysis and the federal review by DHS/FEMA to make recommendations for funding to the
Secretary of Homeland Security.
FY 2022 OPSG funds will be allocated among the eligible jurisdictions based on risk-based
prioritization using the OPSG Risk Assessment described above. Final funding allocations are
determined by the Secretary of Homeland Security, who may consider information and input
from various law enforcement offices or subject-matter experts within the Department. Factors
considered include, but are not limited to threat, vulnerability, miles of the border, and other
border-specific law enforcement intelligence, as well as the feasibility of FY 2022 Operations
Orders to designated localities within border states and territories.
F. Federal Award Administration Information
1. Notice of Award
Before accepting the award, the AOR and recipient should carefully read the award package.
The award package includes instructions on administering the grant award and the terms and
conditions associated with responsibilities under federal awards. Recipients must accept all
conditions in this NOFO and the Preparedness Grants Manual as well as any specific
terms and conditions in the Notice of Award to receive an award under this program.
See the Preparedness Grants Manual for information on Notice of Award.
2. Pass-Through Requirements
Awards made to the SAA for HSGP carry additional statutorily mandated pass-through
requirements. Pass-through is defined as an obligation on the part of the SAA to make funds
available to local units of government, combinations of local units, tribal governments, or
other specific groups or organizations. These entities are defined at 6 U.S.C. § 101(13) as:
• A county, municipality, city, town, township, local public authority, school district,
special district, intrastate district, council of governments (regardless of whether the
council of governments is incorporated as a nonprofit corporation under State law),
regional or interstate government entity, or agency or instrumentality of a local
government.
• An Indian tribe or authorized tribal organization, or in Alaska a Native village or Alaska
Regional Native Corporation.
• A rural community, unincorporated town or village, or other public entity.
Four criteria must be met to pass-through grant funds:
• The SAA must make a firm written commitment to passing through grant funds to
subrecipients;
• The SAA’s commitment must be unconditional (i.e., no contingencies for the
availability of SAA funds);
• There must be documentary evidence (i.e., award document, terms, and conditions) of
the commitment; and
• The award terms must be communicated to the subrecipient.
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Timing and Amount
The SAA must pass-through at least 80 percent of the funds awarded under SHSP and UASI to
the above-defined local or tribal units of government within 45 calendar days of receipt of the
funds. “Receipt of the funds” occurs either when the SAA accepts the award or 15 calendar
days after the SAA receives notice of the award, whichever is earlier.
SAAs are sent notification of HSGP awards via the GPD’s ND Grants system. If an SAA
accepts its award within 15 calendar days of receiving notice of the award in the ND Grants
system, the 45 calendar days pass-through period will start on the date the SAA accepted the
award. Should an SAA not accept the HSGP award within 15 calendar days of receiving notice
of the award in the ND Grants system, the 45 calendar days pass-through period will begin 15
calendar days after the award notification is sent to the SAA via the ND Grants system.
It is important to note that the period of performance start date does not directly affect the start
of the 45 calendar days pass-through period. For example, an SAA may receive notice of the
HSGP award on August 25, 2022, while the period of performance dates for that award are
September 1, 2022, through August 31, 2025. In this example, the 45-day pass-through period
will begin on the date the SAA accepts the HSGP award or September 9, 2022 (15 calendar
days after the SAA was notified of the award), whichever date occurs first. The period of
performance start date of September 1, 2022, would not affect the timing of meeting the 45-
calendar day pass-through requirement.
Other SHSP and UASI Pass-Through Requirements
The signatory authority of the SAA must certify in writing to DHS/FEMA that pass-through
requirements have been met. A letter of intent (or equivalent) to distribute funds is not
considered sufficient. A letter of intent is not a firm commitment and if issued before FEMA
makes the award, then a letter of intent is also not unconditional since it is inherently
conditioned on receipt of funds.
The pass-through requirement does not apply to SHSP awards made to the District of
Columbia, Guam, American Samoa, the U.S. Virgin Islands, or the Commonwealth of the
Northern Mariana Islands. The Commonwealth of Puerto Rico is required to comply with
the pass-through requirement, and its SAA must also obligate at least 80 percent of the
funds to local units of government within 45 calendar days of receipt of the funds.
Under SHSP, the SAA may retain more than 20 percent of funding for expenditures made by
the state on behalf of the local unit(s) of government, such as expenditures by the state in order
to pass through goods or services to local unit(s) of government in lieu of cash. This may occur
only with the written consent, such as a Memorandum of Understanding, between the SAA
and the local unit(s) of government. Separate written consent is necessary for each local unit of
government in which more than 20 percent of funding is retained on their behalf by the state.
The written consent must specify the amount of funds to be retained and the intended use of
funds, including whether any goods or services will be passed through in lieu of cash. It must
also be signed by authorized representatives of both the state and the local unit of government.
States shall review their written consent agreements yearly and ensure that they are still valid.
If a written consent agreement is already in place from previous fiscal years, DHS/FEMA will
continue to recognize it for FY 2022, unless the written consent review indicates the local
government is no longer in agreement. If modifications to the existing agreement are
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necessary, the SAA should contact their assigned FEMA HQ Preparedness Officer.
However, even if a written consent agreement is in place from previous fiscal years, the SAA
must still initially carry out the pass-through documentation for its FY 2022 award and
comply with the four pass-through criteria described above before the written consent
agreement can take effect for purposes of the FY 2022 funding.
Additional OPSG Requirements
The recipient is prohibited from obligating or expending funds provided through this award
until each unique and specific county-level or equivalent Operational Order/Fragmentary
Operations Order budget has been reviewed and approved through an official electronic mail
notice issued by DHS/FEMA removing this special programmatic condition.
3. Administrative and National Policy Requirements
In addition to the requirements in this section and elsewhere in this NOFO, FEMA may place
specific terms and conditions on individual awards in accordance with 2 C.F.R. Part 200.
In addition to the information regarding DHS Standard Terms and Conditions and Ensuring
the Protection of Civil Rights, see the Preparedness Grants Manual for additional information
on administrative and national policy requirements, including the following:
• Environmental Planning and Historic Preservation (EHP) Compliance
• FirstNet
• National Incident Management System (NIMS) Implementation
• SAFECOM Guidance on Emergency Communications Grants
a. DHS Standard Terms and Conditions
All successful applicants for DHS grant and cooperative agreements are required to comply
with DHS Standard Terms and Conditions, which are available online at: DHS Standard
Terms and Conditions.
The applicable DHS Standard Terms and Conditions will be those in effect at the time the
award was made. What terms and conditions will apply for the award will be clearly stated in
the award package at the time of award.
b. Ensuring the Protection of Civil Rights
As the Nation works towards achieving the National Preparedness Goal, it is important to
continue to protect the civil rights of individuals. Recipients and subrecipients must carry out
their programs and activities, including those related to the building, sustainment, and
delivery of core capabilities, in a manner that respects and ensures the protection of civil
rights for protected populations.
Federal civil rights statutes, such as Section 504 of the Rehabilitation Act of 1973 and Title
VI of the Civil Rights Act of 1964, along with DHS and FEMA regulations, prohibit
discrimination on the basis of race, color, national origin, sex, religion, age, disability, limited
English proficiency, or economic status in connection with programs and activities receiving
federal financial assistance from FEMA.
Recipients must complete the DHS Civil Rights Evaluation Tool within 30 days of receipt of
the Notice of Award. Information about this requirement and a fuller list of the civil rights
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provisions that apply to recipients can be found in the DHS Standard Terms and Conditions of
Award. Additional information on civil rights provisions is available at
https://www.dhs.gov/civil-rights-resources-recipients-dhs-financial-assistance and
https://www.fema.gov/about/offices/equal-rights/civil-rights.
Monitoring and oversight requirements in connection with recipient compliance with federal
civil rights laws are also authorized pursuant to 44 C.F.R. Part 7.
In accordance with civil rights laws and regulations, recipients and subrecipients must ensure
the consistent and systematic fair, just, and impartial treatment of all individuals, including
individuals who belong to underserved communities that have been denied such treatment.
c. Environmental Planning and Historic Preservation (EHP) Compliance
As a federal agency, 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
FEMA, including grant-funded projects, comply with federal EHP laws, Executive Orders,
regulations, and policies, as applicable.
FEMA grant funding for new construction or substantial improvement must comply with
Executive Order (EO) 14030, Climate-Related Financial Risk and applicable FEMA
implementing policies in place at the time of disbursement, including FEMA Policy #-206-21-
0003, Partial Implementation of the Federal Flood Risk Management Standard for Hazard
Mitigation Assistance Programs (Interim) (fema.gov) or superseding policies.
Recipients and subrecipients proposing projects that have the potential to impact the
environment, including, but not limited to, the construction of communication towers,
modification or renovation of existing buildings, structures, and facilities, or new
construction including replacement of facilities, must participate in the FEMA EHP
review process. The EHP review process involves the submission of a detailed project
description along with any supporting documentation requested by FEMA in order to
determine whether the proposed project has the potential to impact environmental resources or
historic properties.
In some cases, FEMA is also required to consult with other regulatory agencies and the public
in order to complete the review process. Federal law requires EHP review to be completed
before federal funds are released to carry out proposed projects. FEMA may not be able to
fund projects that are not incompliance with applicable EHP laws, Executive Orders,
regulations, and policies.
DHS and FEMA EHP policy is found in directives and instructions available on the
FEMA.gov EHP page, the FEMA website page that includes documents regarding EHP
responsibilities and program requirements, including implementation of the National
Environmental Policy Act and other EHP regulations and Executive Orders.
The GPD EHP screening form is located at https://www.fema.gov/media-
library/assets/documents/90195. Additionally, all recipients under this funding opportunity are
required to comply with the FEMA GPD EHP Policy Guidance, FEMA Policy #108-023-1,
available at https://www.fema.gov/media- library/assets/documents/85376.
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d. Emergency Communications Investments
If an entity uses HSGP funding to support emergency communications investments, the
following requirements shall apply to all such grant-funded communications investments in
support of the emergency communications priorities and recognized best practices:
• The signatory authority for the SAA must certify in writing to DHS/FEMA their
compliance with the SAFECOM Guidance on Emergency Communications Grants. The
certification letter should be coordinated with the SWIC for each state and must be
uploaded to ND Grants at the time of the first Program Performance Report submission.
• All states and territories must designate a full-time SWIC who has the authority and
resources to actively improve interoperability with emergency management and
response agencies across all levels of government, to include establishing statewide
plans, policies, and procedures, and coordinating decisions on communications
investments funded through federal grants. Note that the designated full-time SWIC
may also be the state’s or territory’s cybersecurity point of contact. SWIC status
information will be maintained by CISA and will be verified by FEMA GPD through
programmatic monitoring activities.
• By the period of performance end date, all states and territories must update the SCIP,
with a focus on communications resilience/continuity, to include assessment and
mitigation of all potential risks identified in the SCIP: natural disasters, accidental
damage (human failures), intentional damage (sabotage, terrorism), cybersecurity, etc.
Following the initial update, the SCIP should be updated on an annual basis. SCIP status
information will be maintained by CISA and will be verified by FEMA GPD through
programmatic monitoring activities.
All states and territories must test their emergency communications capabilities and
procedures (as outlined in their operational communications plans) in conjunction with
regularly planned exercises (separate/addition emergency communications exercises are not
required). Exercises should be used to both demonstrate and validate skills learned in training
and to identify gaps in capabilities. Resilience and continuity of communications should be
tested during training and exercises to the greatest extent possible. Further, exercises should
include participants from multiple jurisdictions, disciplines, and levels of government and
include emergency management, emergency medical services, law enforcement,
interoperability coordinators, public health officials, hospital officials, officials from colleges
and universities, and other disciplines and private sector entities, as appropriate. Findings from
exercises should be used to update programs to address gaps in emergency communications as
well as emerging technologies, policies, and partners. Recipients are encouraged to increase
awareness and availability of emergency communications exercise opportunities across all
levels of government.
States, territories, and other eligible grant recipients are advised that HSGP funding may be
used to support communications planning (including the cost of hiring a SWIC, participation
in governance bodies and requirements delineated above), training, exercises, and equipment
costs. Costs for transitioning to the FirstNet network may also be eligible. More information
regarding FirstNet can be found in the Preparedness Grants Manual.
4. Reporting
Recipients are required to submit various financial and programmatic reports as a condition
of award acceptance. Future awards and funds drawdown may be withheld if these reports
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are delinquent.
See the Preparedness Grants Manual for information on reporting requirements.
5. Monitoring and Oversight
Per 2 C.F.R. § 200.337, FEMA, through its authorized representatives, has the right, at all
reasonable times, to make site visits or conduct desk reviews to review project
accomplishments and management control systems to review award progress and to provide
any required technical assistance. During site visits or desk reviews, FEMA will review
recipients’ files related to the award. As part of any monitoring and program evaluation
activities, recipients must permit FEMA, upon reasonable notice, to review grant-related
records and to interview the organization’s staff and contractors regarding the program.
Recipients must respond in a timely and accurate manner to FEMA requests for information
relating to the award.
See the Preparedness Grants Manual for information on monitoring and oversight.
G. DHS Awarding Agency Contact Information
1. Contact and Resource Information
a. Program Office Contact
FEMA has assigned state-specific Preparedness Officers for the HSGP. If you do not know
your Preparedness Officer, please contact the Centralized Scheduling and Information Desk
(CSID) by phone at (800) 368-6498 or by email at askcsid@fema.dhs.gov, Monday through
Friday, 9:00 AM – 5:00 PM ET.
b. Centralized Scheduling and Information Desk (CSID)
CSID is a non-emergency comprehensive management and information resource developed by
FEMA for grants stakeholders. CSID provides general information on all FEMA grant
programs and maintains a comprehensive database containing key personnel contact
information at the federal, state, and local levels. When necessary, recipients will be directed to
a federal point of contact who can answer specific programmatic questions or concerns.
CSID can be reached by phone at (800) 368-6498 or by e-mail at askcsid@fema.dhs.gov,
Monday through Friday, 9:00 AM – 5:00 PM ET.
c. Grant Programs Directorate (GPD) Award Administration Division
GPD’s Award Administration Division (AAD) provides support regarding financial matters and
budgetary technical assistance. Additional guidance and information can be obtained by
contacting the AAD’s Help Desk via e-mail at ASK-GMD@fema.dhs.gov.
d. Equal Rights
The FEMA Office of Equal Rights (OER), in coordination with the DHS Office for Civil
Rights and Civil Liberties, is responsible for compliance with and enforcement of federal civil
rights obligations in connection with programs and services conducted by FEMA and
recipients of FEMA financial assistance. All inquiries and communications about federal civil
rights compliance for FEMA grants under this NOFO should be sent to FEMA-
CivilRightsOffice@fema.dhs.gov.
e. Environmental Planning and Historic Preservation
GPD’s EHP Team provides guidance and information about the EHP review process to
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recipients and subrecipients. All inquiries and communications about projects under this NOFO
or the EHP review process, including the submittal of EHP review materials, should be sent to
gpdehpinfo@fema.dhs.gov.
2. Systems Information
a. Grants.gov
For technical assistance with Grants.gov, call the customer support hotline 24 hours per day, 7
days per week (except federal holidays) at (800) 518-4726 or e-mail at support@grants.gov.
b. Non-Disaster (ND) Grants
For technical assistance with the ND Grants system, please contact the ND Grants Helpdesk at
ndgrants@fema.dhsgov or (800) 865-4076, Monday through Friday, 9:00 AM – 6:00 PM ET.
User resources are available at https://www.fema.gov/grants/guidance-tools/non- disaster-
grants-management-system
c. Payment and Reporting System (PARS)
FEMA uses the Payment and Reporting System (PARS) for financial reporting, invoicing, and
tracking payments. FEMA uses the Direct Deposit/Electronic Funds Transfer (DD/EFT)
method of payment to recipients. To enroll in the DD/EFT, recipients must complete a
Standard Form 1199A, Direct Deposit Form. If you have questions about the online system,
please call the Customer Service Center at (866) 927-5646 or email ask-GMD@fema.dhs.gov.
H. Additional Information
GPD has developed the Preparedness Grants Manual to guide applicants and recipients of
grant funding on how to manage their grants and other resources. Recipients seeking
guidance on policies and procedures for managing preparedness grants should reference the
Preparedness Grants Manual for further information. Examples of information contained in
the Preparedness Grants Manual include:
• Actions to Address Noncompliance
• Audits
• Case Studies and Use of Grant-Funded Resources During Real-World Incident
Operations
• Community Lifelines
• Conflicts of Interest in the Administration of Federal Awards and Subawards
• Disability Integration
• National Incident Management System
• Payment Information
• Period of Performance Extensions
• Procurement Integrity
• Record Retention
• Whole Community Preparedness
• Other Post-Award Requirements
1. Termination Provisions
FEMA may terminate a federal award in whole or in part for one of the following reasons.
FEMA and the recipient must still comply with closeout requirements at 2 C.F.R. §§
200.344-200.345 even if an award is terminated in whole or in part. To the extent that
subawards are permitted under this NOFO, pass-through entities should refer to 2 C.F.R. §
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200.340 for additional information on termination regarding subawards.
a. Noncompliance
If a recipient fails to comply with the terms and conditions of a federal award, FEMA may
terminate the award in whole or in part. If the noncompliance can be corrected, FEMA may
first attempt to direct the recipient to correct the noncompliance. This may take the form of a
Compliance Notification. If the noncompliance cannot be corrected or the recipient is non-
responsive, FEMA may proceed with a Remedy Notification, which could impose a remedy
for noncompliance per 2 C.F.R. § 200.339, including termination. Any action to terminate
based on noncompliance will follow the requirements of 2 C.F.R. §§ 200.341-200.342 as
well as the requirement of 2 C.F.R. § 200.340(c) to report in FAPIIS the recipient’s material
failure to comply with the award terms and conditions. See also the section on Actions to
Address Noncompliance in this NOFO or in the Preparedness Grants Manual.
b. With the Consent of the Recipient
FEMA may also terminate an award in whole or in part with the consent of the recipient, in
which case the parties must agree upon the termination conditions, including the effective
date, and in the case of partial termination, the portion to be terminated.
c. Notification by the Recipient
The recipient may terminate the award, in whole or in part, by sending written notification to
FEMA setting forth the reasons for such termination, the effective date, and in the case of
partial termination, the portion to be terminated. In the case of partial termination, FEMA
may determine that a partially terminated award will not accomplish the purpose of the
federal award, so FEMA may terminate the award in its entirety. If that occurs, FEMA will
follow the requirements of 2 C.F.R. §§ 200.341-200.342 in deciding to fully terminate the
award.
2. Program Evaluation
Recipients and subrecipients are encouraged to incorporate program evaluation activities
from the outset of their program design and implementation to meaningfully document and
measure their progress towards meeting an agency priority goal(s). Title I of the Foundations
for Evidence-Based Policymaking Act of 2018 (Evidence Act), Pub. L. No. 115-435 (2019)
urges federal awarding agencies and federal assistance recipients and subrecipients to use
program evaluation as a critical tool to learn, to improve equitable delivery, and to elevate
program service and delivery across the program lifecycle. Evaluation means “an assessment
using systematic data collection and analysis of one or more programs, policies, and
organizations intended to assess their effectiveness and efficiency.” Evidence Act § 101
(codified at 5 U.S.C. § 311). Evaluation costs are allowable costs (either as direct or indirect),
unless prohibited by statute or regulation.
3. Period of Performance Extensions
Extensions to the period of performance (POP) for this program are allowed. Extensions to
the POP identified in the award will only be considered through formal, written requests to
the recipient’s FEMA Preparedness Officer and must contain specific and compelling
justifications as to why an extension is required. Recipients are advised to coordinate with
the FEMA Preparedness Officer as needed when preparing an extension request. Please see
the Preparedness Grants Manual for more information.