unfolds, you can and should add tracking codes for spe- cific locations or other designations of costs needed for each FEMA Project Worksheet (PW), the form they will use for tracking costs and providing approvals.

PW Level: Track all costs at the Project Worksheet (PW)

level. FEMA prefers to have extremely specific PWs. You can often get by with one PW covering all police work on the first day of an emergency and separate ones covering all fire, emergency medical, public works, and other immedi- ate costs. But after that very immediate response, FEMA is going to want to see detailed charges — usually down to very specific geographical detail. You need to set up tracking codes at the PW or lower levels to ensure reimbursement. Tis applies to force account expenses, contractor costs, and any other miscellaneous expenses. You should set up your accounting structure to accommodate this level of tracking.

Damages Only; No Improvements: Te general guide- line is that FEMA will pay to replace only what was dam- aged — not for an improvement. What is an improve- ment? Even if it is a cheaper aleternative to redesign or take a different route, FEMA will reject reimbursement if it was an “improvement.”

Audit/Compulsory Refunds to FEMA: Even if FEMA pays the county, FEMA can later force a refund if the pay- ments are deemed to be too much or to not qualify (like an “improvement”). So documentation may be required to keep money that has already been paid by FEMA.

County Employee Compensation: FEMA will pay only additional, disaster-related costs. One of the most difficult issues relates to employee compensation. Te result is that it is, counter-intuitively, often cheaper to hire contractors than assign work to county staff. You should understand how FEMA will treat “force account” or county staff la- bor vs. contractors. FEMA will rarely question paying a bill from outside contractors (i.e., persons not already on the county payroll) as long as the amount seems reasonable. However, FEMA takes a much different view of reimburse- ments for emergency work done by your own county staff. For example, if you reassign staff to do clean-up work dur- ing their regular hours, FEMA will not reimburse you since they will not see any additional cost. If you then have to pay staff overtime to catch up on their normal work, FEMA will not pay that either because it is not disaster related. If you hire a contractor to do the work, you avoid the issue. (“Force account” costs also include equipment and sup- plies, but these are normally relatively straightforward. But


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do not try to charge equipment for 24 hours because it was at the disaster site for 24 hours when you have an operator for only eight hours.)

No Reimbursement for Volunteers: You can be reim- bursed only for expenses that are your legal responsibility. What about all of those small non-profit organizations that helped out during the response that do not have the exper- tise to complete all of the forms and keep all of the docu- mentation? Most often they would not be eligible for FEMA reimbursement. One way to try to handle this is to set up contracts with your non-profits before any disaster strikes that make it your government’s responsibility to provide the service (e.g., care and shelter) through the non-profit. You pay the non-profit for their services and it should make the costs eligible for reimbursement.

Active vs. Inactive: Facilities must be active at the time of the emergency. Yes, this means that an older building no longer in use will not be repaired or replaced with FEMA money. But it also means that a new facility under construc- tion is not eligible for FEMA funding. Be reasonable in your expectations. Remember, even if

you receive the funds up front, you can lose them years later in audits. Te auditors feel no responsibility to honor or be consistent with approvals made throughout the process.

FEMA Staff: Te FEMA staff you will be working with right after a disaster will probably be temporary or contract staff who may not be completely familiar with FEMA rules. And the rules may be changing. So if you get a response you do not like, do not just accept it. Appeal it up the chain un- til you exhaust your possibilities. Of course, you need to use good judgment about how often to do this and how much money is involved so you do not dilute the response to your really serious, larger disputes.

Audit: When your disaster is in the news, people (in- cluding members of Congress) care about helping you. Do whatever you can and use whatever pressure you can bring to bear to have your costs audited as soon as possible. If you have completed your immediate emergency response cost documentation, you can ask for an audit of those costs — even if the more permanent repair work is still under way. If you learn from those audits, you may be able to be more successful securing reimbursement for the permanent work. If you are being audited seven years later, policymakers and the public will not come to your aid if FEMA rules they are taking back money for questioned or undocumented costs — you will be old news.


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