By Kevin Mulrooney
Without a doubt, receiving a FEMA Assistance to Firefighters Grant Program (AFGP) award is much more fun than managing it. Especially since most fire departments submit several applications under the various programs over many years until they receive the happy news.
But managing the award is equally as important as receiving it. When our clients receive awards, we present them with some common sense guidelines on how to document expenditures, avoid conflicts, and maintain good records. Our recommendations are based much more on logical book keeping than any accepted fiscal standard. In fact, it’s largely based on how we operate our business practices.
“The number one issue we have with our awardees comes within the first minutes of award notification,” said Tom Devaney, Director of Operations at JSK Inc/Grant-Guys. “The initial question almost immediately is, ‘Can we use the money for something else? We don’t want that anymore.'” The short answer is no. If you applied for an item and were awarded that item, it is highly unlikely the award will be greatly altered. This is is because the questions are computer scored for various items, and the narrative was approved by the peer review committee for that specific item.
The reality is that much of the AFGP is based on the honor system. As citizens and firefighters, it’s up to us to be honest and keep good records. But many awards are audited. Recently, one of our clients was the subject of an AFGP desk review. We assisted the fire department for two reasons: first, we wanted to learn what should be documented to help our other clients in the future; and secondly–and most importantly–it was the right thing to do.
Our suggestions at the time of the award including the following items:
- print out quarterly reports and semi-annual reports
- print out a copy of the application and award package
- keep usernames and passwords together with the application in a secure place, keeping passwords up to date
- keep all purchase orders, invoices, cancelled checks, and receipts together
- track serial numbers and location of purchased equipment
- and in the case of SAFER awards, maintain all payroll and employment data as required.
To our pleasant surprise, it is our experience that the overwhelming majority of fire departments meet and exceed these simple guidelines. However, in assisting with the desk review, we found that the FEMA staff appeared more interested in the “how” they expended funds rather than the proof of the purchase. For instance the desk reviewers did not ask for serial numbers or invoices, but they did ask about their “processes”: how was it that decisions are reached, who has the authority to make decisions, or what happens in the event of cost overruns. This fire department, which is a form of fire district under NYS law, thankfully was required to have accounting practices well above what could ever be expected in a routine audit. But it did not have a written list of practices as to how funds were dispersed. Everyone on the Board knew that receipts presented for payment were to be voted on by the Board, and that purchases needed to be in line with the award. But nowhere did it actually have a written policy to document that. It was a problem which had a quick resolution in this case, but it draws attention to some of the rules that FEMA might be looking for. Of the 18 questions asked during the review, here are nine important ones. In the event of an award, we recommend establishing a simple three-ring binder and placing the following policies and procedures in them in WRITTEN FORM.
1. Organizational charts
2. Fiscal year reviews separating federal vs non-federal funds
3. Policy on who has authority to commit funds, approve policies, and accepts proposals,
4. How are amendments or reclassifications to the original award made, and by whom?
5. Who reviews each request for funds?
6. Where is the accounting manual kept?
7. Who determines the reasonableness of purchases, and what is reasonable?
8. What are the retention periods of your documents?
9. What documents are needed for each purchase?
Requirements for SAFER awardees may differ by requesting staffing rosters, hiring policies, and related employment documents usually retained by any employer. Department SOPs are also often requested. Questions about layoffs, job descriptions, time and attendance polices. Hires are also required to be Firefighter 1 & 2 within 24 months and certificates may have to be forwarded to the auditor.
As you can see, many of these questions are what can be expected of any business or government agency. But incredibly, there are some agencies that cannot comply with even these simple policies. It’s important to realize that this is the people’s money. If your agency chooses not to follow general accounting practices, that’s fine–but don’t expect to receive federal funding. Since you are now spending the government’s money (provided by the taxpayers), you now have an obligation to follow their rules. It is after all their money, and if you can’t follow these steps then you shouldn’t apply. FEMA has a responsibility to make sure tax money is spent honestly.
The time to discuss these issues is before you apply for aid, not after you receive the award. If you are on the grant committee, or if you have retained a professional grant writer, you need to make these requirements known to the department leadership.
Audit requirements are not a reason not to apply for funding. If anything, it will make your agency more efficient in the long run. The possibility of an audit or review is a great excuse to get a non-compliant fire department to be a more professional organization.
Kevin Mulrooney is a 30 year volunteer firefighter/EMT/Hazmat Tech. He is the owner of JSK Inc., “the Grant-Guys.” JSK is NY’s largest fire grant writing firm securing a record $2 million by round four of the 2013 AFGP. JSK represents 200 fire departments in nine states.