AUG 0 9 2013 Mr. Jimmy Gianato Director and Homeland Security Advisor West Virginia Division of Homeland Security and Emergency Management Building 1, Room 1900 Kanawha Boulevard, East Charleston, West Virginia 25305-0360 Dear Mr. Gianato: US. Department of Homeland Security Region ill One independence Mall, 61h Floor 615 Chestnut Street Philadelphia, PA l9106-4404 The purpose of this letter is to report the results of the ?nancial monitoring on-site visit conducted from June 25 through June 27, 2013 at by the Federal Emergency Management Agency (FEMA), Region Grants Division. Region reviewed the following grant programs: Grant Number Program Grant Amount Fluid? Remaining Severe Repetitive Loss $272,263.00 $5,696.75 1 EMF-2009-PC-0005 Pro-Disaster Mitigation $859,032.75 Closed Competitive I EMP-2012-GR-8005 Community Assistance $107,700.00 $71,820.99 3 Program - State Support Services Element EMP-201 Community Assistance $95,700.00 Closed Program State Support Services Elemeigt Cooperating Technical $180,000.00 Closed Partners 1 EMF-20 1 O-GR-S 020 Cooperating Technical $175,000.00 $84,65 8.35 Partners EMF-201 Cooperating Technical $90,000.00 No drawdowns as of Partners visit date Emergency Management $3,63 7,064.00 $907,970.00 Performance Grant Program Emergency Management $3,618,847.00 $1,397,289.00 BMW -201 l-EP-0007l Performance Grant Program BMW-20 Emergency Management Performance Grant Program $3,742,786.00 No drawdowns as of visit date Hazard Mitigation Grant Program $6,101,623.00 $2,159,739.ERCENCEM, I'iui?sil. .- 1 I .l 0117. E0 1' Grant Number Program Grant Amount Fluid? Remaining A 188 Hazard Mitigation Grant $286,743.00 $51,041.98 Program 1893DRWV P00000005 Hazard Mitigation Grant $1 393,61 1.00 $487,277 .61 Program Hazard Mitigation Grant $558,656.00 $355,762.25 Program Hazard Mitigation Grant $1,566,519.00 $665,127.94 Program 4071DRWVIOTH Individual Assistance $252,727.00 $32,440.40 i Public Assistance $22,605,185.00 $1,358,736.22 . Public Assistance $7,063,543.00 ?430345-46 I Public Assistance $4,002,975.00 ?0 as 0f Public Assistance $5,852,529.00 No drawdowns as of I visit date 406 Public Assistance $2,939,468.00 No di'awdowus as of I. I visit date Public Assistance $1,284,257.00 No drawdowns as of visit date The purpose of the review is to provide guidance and to enhance your efforts in managing Federal funding. The following is a summarized list of observations and associated corrective actions resulting from our visit to your of?ce: I Award(s) Target Observation Recommended Corrective Action(s) Response Affected Due Date . Submit a ?nancial monitoring plan All PUbllC 1, Financial sub-recipient monitoring for ?scal year 2014 identifying the Assistance 2013. being 900??de for Public Public Assistance sub-recipients to be awards ASSiSiance- FEMA region is monitored along with scheduled dates curfele working Will? monitoring will be conducted. corrective action . Upon receipt ofthe plan and Plan that add-[65333 the 1301? Of schedule, FEMA regional of?ce will programmatic monitoring for work with to identify Public Assistance. which monitoring reports we will require a copy of and the associated due dates. No sub?recipient ?nancial and Develop a sub-recipient ?nancial and Emergency October 25, programmatic site visits and/or monitoring site visit Management 2013 desk reviews have been conducted and desk review schedule for FY Performance in FY 2013 with regard to sub- 2014 and pmvide Region 3 with a Grant recipients of EMPG grant funds copy ofthe schedule Programs (44 CFR 1140)- . Upon receipt of the plan and schedule, FEMA regional of?ce will 2 work with to identify which monitoring reports we will require a copy of and the associated due dates. Investigate the possibility of funding the hiring of additional staff for monitoring purposes by expending or reallocating funds from open EM PG awards. Sub-recipient award information not reported in the subaward awarding system as required by the Federal Funding and Awarding Transparency Act (FFATA). Register at the FFATA reporting website, and follow the instructions for registration and sub?award reporting. Report all sub-grantee awards greater or equal to $25,000 as of October 1, 2010 into and notify FEMA regional of?ce once complete. All grants November A l, 2013 It is important to continue to strengthen internal controls and resolve any grants management and administration deficiencies as the effective oversight and management of Federal. grant resources is critical. Additionally, programs and projects undertaken by grantees must be consistent with approved plans and comply with applicable laws, rules, regulations and program guidance. is working with FEMA Region on implementing their Public Assistance programmatic monitoring corrective action plan (CAP) and would like to commend you on meeting your milestones with that CAP. The recommendations made as a result of this visit, will continue to strengthen your management of grant funds. Enclosed is a copy of the Site Visit Protocol which contains detailed information regarding our observations, along with Appendix E, FEMA Region Programmatic Monitoring Report for the 2010, 201 1, and 2012 Emergency Management Performance Grant Programs (EMPG). Please note that Appendices A through C, referred to in the Site Visit Protocol, are not enclosed with this letter but provided to FEMA Headquarters. Those policy and procedure documents were provided to us by your staff for our review during the site visit. We would like to take this opportunity to thank you and your staff for being very helpful and cooperative in providing Region Grants Management Staff with the materials requested during the site visit. We found your staff to be knowledgeable, supportive, and eager to ensure the success of EMA funding efforts. If you have any questions, please feel free to contact either myself at (2 15) 931-5569 or Aliyu Mohammad at (215') 931-5744 or Sincerely, i lanice P. Barlow fxf?rector, Grants Division Enclosures cc: FEMA HQ GPD Regional Coordination and Oversight Branch (RCO) Department of Homeland Security Federal Emergency Management Agency Monitoring Protocol for State, Local, and lndian Tribal Governments Granteelnform?ition. 3? Grantee Name: West Virginia Division of Homeland Security and Emergency Management Type of Organization: State Grantee Contact: Jimmy Gianato Title: DirectOr Telephone: 304 558-5380 1 Fax: 304-344?4538 Ema": Jimmy Gianato@wv gov Address: 1900 Kanawha Boulevard, Building 1, Room EB-80 City: Charleston I State: LWV Zip: 25305-0360 I Country: i USA staff: Lisa Specials, Controller; Greg Meyers, PA Officer; Tom Dingess, Director of Administration, AI Lisko, Director of Mitigation and Recovery; Mark Wallace, Mitigation Officer Other individuals involved: WVDMAP Staff: Michael Cutlip, Grant Administrator 1 Combined Entrance Conference for and WVDMAP Review information Desk Review or Site Visit: Desk Review Final Contact Date! Site Visit I Site Visit conducted from June 25 to June 27, 2013 Completion Date: Region: 3 Region 3 Grants Management Specialists: Aliyu Mohammad, Karen Van Osten, I Hydie Miller 5. Remn 3 Grants Program Manager: Dustin Brosius Regiona Tracking Number Site Visit (Optional): NIA FEMA Reviewer(s): Grant information l' Start End or Funds Grant Number Program 1 Grant Amount Remaining Date POP Date 1 EMP-201 0-SR-0001 Severe Repetitive Loss i $272,263.00 $5,696.75 82512010 812512013 I EMP-ZOOQ-PC-0005 Pro-Disaster Mitigation Competitive $859,032.75 Closed Community Assistance Program - State Support Services Eiement $71,820.99 41112012 9i28i2013 Community Assistance Program - EMP-ZOOQ-GR-5012 Cooperating Technical Partners $180,000.00 Closed EMF-2010-GR-5020 Cooperating Technical Partners $175,000.00 $84,658.35 i 9i1i2010 91112013 Department of Homeland Security Federal Emergency Management Agency Monitoring Protocol i . . .. No drawdowns EMF-2011-GR-7012 Cooperating Technical Partners 590,000.00 as of visit date 911412011 911412014 Emergency Management 2010 EP-E0-0036A Performance Grant Program $3,637,064.00 $907,970.00 101112009 913012013 Emergency Management EMW-2011-EP-00071 Performance Grant Program $3,613,847.00 $1,397,289.00 101112010 913012013 Emergency Management No drawdowns EMW 2012-EP-00069 Performance Grant Pm ram $3,742,786.00 as of visit date 101112011 913012013 Hazard Mitigation Grant Program $6,101,623.00 $2.159.739-19 511512009 11612015 Hazard Mitigation Grant Program $236,743.00 $51,041.98 31212010 1113012014 Hazard Mitigation Gran_t Program $1,393,611.00 $487,277-51 312912010 513112015 Hazard Mitigation Grant Program $558,656.00 $355,762.25 412312010 513112015 19180RWVP00000005 Hazard Mitigation Grant Program $1,566,519.00 $665,127.94 512412010 513112015 4071 DRWVIOTH individual Assistance $252,727.00 $32.440-40 712312012 112312014 16380RWVP00000001 Public Assistance $22,605,185.00 31.353.735.22 511512009 1111512013 Public Assistance $7,063,543.00 $1,430,745.46 312912010 912912014 . No drawdowns - 19030RWVP00000001 Public Assistance $4,002,975.00 as of visit date 412312010 1012312013 . . No drawdowns 40590RWVP00000001 Public Assustance $5,652,529.00 as of visit data 311612012 911612016 No drawdowns 4061 Public Assistance $2,939,468.00 as of visit date 312212012 912212016 . No drawdowns 4071 Public Assistance $1,284,257.00 as of visit date 712312012 112312017 Monitoring History- Are any of the monitored grants cio sed or expired? 1 Yes, see above table for detail. require follow-up during 1 Were any significant problems identified during quarterly reviews of the FRISF-425s that he financial monitoring review? No issues with submitted Federal Financial Reports (SF-4255) over the past year. Has the grantee received priorfinancial monitoring reviews? I i September 2012 and April 2011 Has the grantee received prior programmatic monitoring visits? Do any prior monitoring reports have actions that still need to be resolved? Corrective actions regarding Disaster Pu 2011 site visit and repeat A4 33 audit findings were not rose the need to improve Public Assistance sub-recipient monitoring. blic Assistance Grant Programs identified during the Fiscal Year ived. These corrective actions would address Was a pro-monitoring meeting conducts with the Programmatic Staff andior i Dustin Brcsius, Region 3 EMPG Grant Program Manager attended the site visit. ed Corrective Action-s Award(s) Target region lii is curre Assistance. with corrective action plan that addresses the lack of programmatic . monitoring for Public ntiy working to be monitored along with scheduled dates monitoring will be conducted. Upon receipt of the plan and schedule, FEMA regional office _wiu regimens/ease Observation Recommended Corrective Action(s) Affected Egs?nonse Due Financial sub-recipient - Submit a financial monitoring plan All Public October 1, monitoring not being conducted for fiscal year 2014 identifying the Assistance 2013. for Pubiic Assistance. FEMA Public Assistance sub-recipients awards Department of Homeland Security Federal Emergency Management Agency Monitoring Protocol identify which monitoring reports we will require a copy of and the associated due dates. . 1 No sub-recipient financial and . programmatic site visits andfor desk reviews have been conducted in FY 2013 with regard to sub-recipients of EMPG grant funds (44 CFR 0 13.40). Develop a sub-recipient financial and programmatic monitoring site visit and desk review schedule for FY 2014 and provide Region 3 with a copy of the schedule. Upon receipt of the plan and schedule, FEMA regional office will work with to identify which monitoring reports we will require a copy of and the associated due dates. investigate the possibility of funding the hiring of additional staff for monitoring purposes by expending or reallocating funds from open EMPG awards. Emergency Management Performance Grant Programs October 25, 2013 Sub-recipient award information not reported in the subaward awarding system as required by the Federal Funding and - Awarding Transparency Act (FFATA). Register at the FFATA reporting website, and follow the instructions for registration and sub-award reporting. Report all sub-grantee awards greater or equal to $25,000 as of October 1,2010 into and notify FEMA regional office once complete All grants November 1, 2013 Response due to FEMA by: See target due dates referenced above. "Additional Review'Notesicomments - . Region ill has visited annually for the past three years (two regularly scheduled site visits and one technical assistance visit). Our objective this year was to: 0 Ensure that had adequate policies, processes, and systems in place to appropriately manage FEMA awards consistent with federal regulations 0 Assist and advise WV on grant processes and provide guidance to improve administrative efficiencies and programmatic effectiveness - Determine if progress had been made towards on (past) CAP implementation and Specifically, improved Public Assistance sub-recipient monitoring. Report to FEMA regional office the effectiveness of its grant programs and the stewardship of public funds by WV Division of Homeland Security and Emergency Management. Section 1: Determining the Adequacy of Financial Systems Guidance standards female: nae-nemesis:th Source i For States: A State must expand and account for grant funds in accordance with State laws and 1- procedures for expending and accounting for its own funds. Fiscal control and I 44 CFR 13.20 8f. Department of Homeland Security Federal Emergency Management Agency Monitoring Protocol i i i i . accounting procedures of the State. as well as its subvgrantees and cost-type contractors, must be suf?cient to: Verify that the grantee has fiscal control and accounting procedures in place which permit the preparation of ?nancial reports required by 44 CFR Part 13. Verify that the grantee has ?scal control and accounting procedures in place which permits the tracking of funds to the lowest entity, also ensuring the appropriate segregation of funds. Comments: All awards are set up with identifiable account numbers and managed in the Financial information Management System (FIMS). This is the grantee?s primary accounting system currently utilized for tracking grant activity and reporting. Enterprise Resource Program (ERP) is the new electronic system currently in development which will replace FIMS. All budget entries and expense allocation are done manually and verified by the Comptroller with approval signatures from both the Director of Administration and Director of Mitigation and Recovery respectively. Grantee submitted a Grantee Self-Certification that reported no significant changes have been made to their financial reporting, accounting and internal control processes since the last site visit in FY 2011. (Appendix A). For Local and Other Governmental Grantees: i I . ?w ledgers. There will be an Financial reporting. Verify that the grantee?s financial system provides for accurate, 44 CFR 13.20 (am) current, and complete disclosure of the financial results of grant activities in accordance with the ?nancial reporting requirements of the grant or sub-grant. Comments; Grantee submitted a Grantee Self-Certification that reported no significant changes have been made to their financial reporting, accounting and internal control processes since the last site visit in FY 2011 (Appendix A). However, the current financial system, financial system called the Enterprise Resource Program scheduled for 2015. staff believes that this new system will improve grantee and sub-recipient financial monitoring. Manual entry of budget items for grant items will not be required under the new system. The new system will enable the internal spreadsheet to link to individual grantee ability to match SmartLink and PARS reports to actual grantee figures using the 2. FIMS, is going to be replaced with a much improved and integrative (ERP). Full implementation of this new system is new ERP system. Financial information for HMGP projects is tracked in FUNDtrak and then the financial software used by WV. Accounting records. Verify that grantee maintains records which adequately identify the source and application of funds provided for ?nancially- assisted activities. These records must contain information pertaining to grant or sub-grant awards and i authorizations, obligations. unobligated balances, assets, liabilities. outlays or expenditures, and income. 44 A. Comments: The grantee reviews sub-grantee deliverables and expenditures using the Project Worksheet method of review for Public Assistance applicants. Public Assistance sub-recipients are paid on a reimbursement basis. Only small applicants (less than $67,500) are paid in advance, so that the work can be accomplished as needed. The advance payment option is reserved only for those small counties who do not have sufficient funding to initiate the project. The method of monitoring Public Assistance is to use the Final inspection Report (Fi? as the financial?control document. internal control. Verify that the grantee has effective control and for all 44 CFR 13.20 grant and sub-grant cash. real and personal property, and other assets. Verify that grantees adequately safeguard all such property and must assure that it is used solely for authorized purposes. i L. Comments: WV Staff believes that one of their strongest internal controls is their process of obtaining four signatures for all payments (for HMGP) and three signatures for PA and EMPG. A spreadsheet with individual Assistance {iA} expenses is submitted to DHSEM from the WV Department of Health and Human Services; The grantee__is aware of the Cash Management improvement Act (CMIA). The 4 Department of Homeland Security Federal Emergency Management Agency Monitoring Protocol key issue is the need to minimize cash on hand. Due to the reimbursement method of payment, CMIA I issues are minimized. I Budget control. Verify that the grantee compares actual expenditures or outlays with 44 CFR 1320 budgeted amounts for each grant or sub-grant. Comments: . FEMA staff received confirmations from both Comptroller and Director of Administration that all expenditures are matched against the approved budget to ensure the charges are aliocable and sufficient funds availabte to process payments. The Comptroller, and the HMGP staff (the SHMO) confirm that and are showing the same financial information. The disaster number and project number must be reflected on all invoices, and verified by staff before charges are applied to a particular project. Allowable cost. Verify that the grantee foilows applicable 0MB cost principles, agency 44 CFR 13.20 6. program regulations, and the terms of grant agreements in determining the reasonableness. and allocabiliiy of costs. Comments: I Verified. All costs reviewed were determined to be allowable and allocable to the project with back up i documentation provided to validate the eit?nditures. Source documentation. Verify that the grantee?s accounting records are supported by i 44 CFR 13.20 i appropriate source documentation such as cancelled checks, paid bills, payrolls, time - 5. n. 7' and attendance records, contract and sub-grant award documents, etc. (also see Section Review of Costs). 1 Comments: Source documentation was provided by the Comptroller for the random drawdown reimbursement requests of the Non-Disaster Mitigation and Preparedness Grant Programs reviewed during_the visit. Cash management. Verify that the grantee has procedures for minimizing the time 44 CFR 13.20 i elapsing between the transfer of funds from the US. Treasury and disbursement by i 44 CFR 13-21 8- grantee. In addition, Verify that grantee has procedures in place to monitor sub- grantee cash on hand (also see Sub-recipient Monitoring). i _l Comments: Major projects (PA projects exceeding $67,500) are funded on a reimbursement basis. Smaller projects and applicants are paid in advance. For large applicants such as the WV Division of Highways, Department of Transportation, small projects are not reimbursed before the project is completed. The Division of Highways bills at the end of the project for projects small and large. Some individual Assistance (lA) funding goes directly from FEMA to the disaster survivor. Other IA assistance is billed by the WV Department of Health and Human Resources. Section 11: Compliance Review Award?File Documents Overviewtonesite Review Only) Ensure that the grantee maintains grant tiles that contain the following documentation: . Copy of Request for Application (To include: EmailiAttachments and Recipients Application) Award Package (To include: Letter. Award documenb?Assistance AwardiAgreement Articles, with the Period of Performance and CFDA Number listed) 1 2 3. Amendment Extension Requests/Approvals (CFR 4. Amendment Budget Change Requests/Approvals (CFR Amendment Scope Narrative/Change Requests/Approvals (CFR i . Performance Reports (CFR 13.40 or (1-2) a Financial Reports (CFR 13.41) Department of Homeland Security Federal Emergency Management Agency Monitoring Protocol All related supporting documentation of expenditure activity; grantee expenditure activity and sub?recipient 7' award tiles with suppor?ng e?nditure documentation Comments: A random sampling of Disaster, Non-Disaster Mitigation and National Preparedness official grant files were reviewed to confirm that the files contained the award and supporting documentation. finest Ana?rdilFinancial Administration . A Guidance 1 Source PaymentAdvances. if the grantee requests advances, verify that there are procedures 1 44 CFR 13.21 1. in place to minimize the time eiapsing between the transfer of the funds and their disbursement by thegrantee. i Comments: i operates on a reimbursement basis. if a iocat county is purchasing a house which is being I acquired for demolition under Non?Disaster Mitigation, then closing costs may be advanced to the county "prior to settlement. interest earned. Verify the grantee tracks all interest earned. Except for interest earned 44 CFR 13.21 2 on advances of funds exempt under certain acts. grantees shall but at least quarterly, remit interest earned on advances. The grantee may keep interest in amounts up to 5100 per year for administrative expenses. i Comments: i WV does not earn interest from FEMA Grant Programs. Chartres Durino the Grant Period of Performance. Verify that grantee is only charging 44 CFR 1323(8) costs to the grant resulting from obligations of the period of performance unless .i cthenrrise permitted by EMA. Comments: Verified. staff confirmed that all charges incurred were during the grant period and payments were reimbursement for services rendered. FEMA staff further validated this through a review of the drawdown reimbursement requests for Disaster, Non-Disaster and Preparedness Programs. of Matching/Cost Sharing Funds. Verify that alt matching or cost-sharing is 44 CFR 1324(3) allowable under the program guidance. program reguiations, and applicable cost '2 principtes. Comments: WV uses a formula for its quarterly financial reporting to ensure that the state shares and federal shares . are correct. Unique accounting codes identify state shares and federal shares. Contributions and Donated Services. Verify that all in-kind contributions and 44 CFR 13-2403) 5. donated services are allowable, documented, and properly valued as specified in the l' and (ti - program guidance and regulations. 4: Comments: 5 Not applicable 6 . Program income. Verify that ail program income is directly generated by a grant 44 CFR 13.25(b) supported activity. Comments: Not applicable. Use of Program income. Verify that program income is used in accordance with the 44 CFR 1325(1)) 7 award terms and conditions. (Note: if the use of program income is not specificaliy addressed in the award. then the default is to deduct program income from total program costs.) Department of Homeland Security Federal Emergency Management Agency Monitoring Protocol Comments: Not applicable. A-133 Audits. Verify that grantee is obtaining audits as required by applicable laws, 44 CFR 13.26 OMB Circulars. and the program guidance. Also, verify that the grantee is monitoring 0MB CifCUlaiA-133 its sub-grantees to ensure they are receiving A433 audits as appropriate. 5 Comments: has had repeated A-133 audit findings for several years. Some audit findings (such as weak cash management leading to cash-on-hand) have been resolved. A more persistent problem has been inadequate financial and programmatic monitoring of Public Assistance sub-recipients. Several Corrective . Action Plans have been put in place to address this problem but they were not successfully implemented. A new Corrective Action Plan (CAP) was implemented by on May 17, 2013. The plan includes Improved training for Public Assistance sub-recipients, and periodic site visits or desk reviews to monitor 1; sub-recipients. FEMA Region Ill is currently monitoring this CAP to ensure its implementation is 5 successful. Details of CAP monitoring plan were sent to on June 28, 2013. (Appendix D) 9. (sub grant or contract) to any party which is debarred, suspended, or otherwise ineligible from participatingin Federal assistance programs. i WV verifies eligibility by conducting a search of sub-granteesivendors through the Excluded Parties List System (EPLS) website. Sub-grantees are required to sign certifications as to debarment, suspension, andlor ineligibility in order to i i partipate in a federal assistance program awarded to WV. Failure to do so will negate the authorization of any respective contract. - Debarred or Suspended Awards. Verify that the grantee does not make any award i 44 CFR 13.35 i Post Award: '_Propew,,eqIipment, and Procurement l- Guidance . he b1 *Use of Real Property. Verify that any real property purchased With Federal funds is 44 CFR 13.31 i being used for its originally authorized purpose. 5 Comments: i i Source _i Not applicable for Public Assistance and National Preparedness grant programs. However, houses may be acquired for demolition purposes under the Non-Disaster Mitigation grant programs. 1 Procedures for Discosition of Real Pronertv. Verify that grantee maintains procedure 44 CFR 13.31(c) 2. I for disposition of real property and the proper reimbursement of funds to FEMA when I i necessary. Comments: A copy of the Deed for properties acquired for demolition purposes is submitted to DEMA and the State of .. . i556 a?es?? 3 Management. Verify that the State uses, manages, and diSposes of equipment 44 CFR 13.32ib) acquired under a grant by the State in accordance with State laws and procedures. Comments: Verified. abides by the state?s regulations regarding disposal of equipment. it is the sub- recipient?s responsibility to assign property tags for equipment purchased with federal funds and provide a detailed equipment list to the grantee that lists the property tag number and location of the equipment. 7 Department of Homeland Security Federal Emergency ManagementAgency Monitoring Protocol Wuhan-the a site visit, the equipment purchased is inspected and compared with the equipment list on file from the sub-recipient. For Local and Other Governmental Grantees: Management Procedures. Ensure that the grantee has procedures in place to manage 44 CFR 13.32id) equipment and verify that they meet the requirements below: 0 Verify that grantee maintains all necessary property records which include a description of the property, as serial number. acquisition date, etc. i - Verify that grantee has taken a physical inventory once every two years and i Management Procedures. Verify that the State procures property and services under 44 CFR 1336(3) i the grant, following the same policies and procedures it uses for procurements from its 5. non-Federal funds. Verify that the State ensures that every purchase order or other 3 contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. 1; Comments: Grantee submitted a Grantee Self-Certification that reported no significant changes have been made to their financial reporting, accounting and interns! control processes since the last site visit in FY 2011. (Appendix A). 4' that the results have been reconciled with property records. 1' - Verify that grantee maintains a control system to ensure adequate safeguards 1 i to prevent against loss, damage, or theft. 5 I 0 Verify that the grantee has developed adequate maintenance to keep the i I ?peny in good condition. I 1 Comments: _i States: abides by the State of West Virginia?s purchasing laws and guidelines. More information can be found at: For Local and Other Governmental Grantees: Procurement Policies. Verify that grantee maintains procurement policies that re?ect 1 44 CFR 13.3603) 6' . applicable Federal, state. and local iaws. I (1) Comments: Code of Conduct. Verify that grantee maintains a written code of standards of conduct 5 44 CF 7. governing the performance of their employees engaged in the award and the 13.36(bi(3) administration of contracts. 3 Comments: i TProcurement Records. Verify that grantee maintains procurement records sufficient to 44 CFR i 8. detail the significant history of procurement rationale for the method of . procurement, selection of contract type). i Comments: Protest Procedures. Verify that the grantee has protest procedures to handle and 44 CFR 9. resolve disputes relating to their procurements and shall in all instances disclose .?ti??ima?il?aa??g harshest to the awarding agency. Department of Homeland Security Federal Emergency Management Agency Monitoring Protocol Comments: 10 Full and Open Competition. Verify that all procurement transactions were conducted in 44 CFR 13.36ic) a manner providing full and open competition consistent with all Federal standards. Comments: Contract provisions. Verify that the grantee's contracts contain all applicable 44 CFR 1336(5) 11 provisions. Federal agencies are permitted to require changes. remedies, changed I conditions. access and records retention, suspension of work, and other clauses I approved by the Office of Federal Procurement Policy. 5 Comments: i i i.Monitoring and-Records Guidance Source Monitoring by grantees. Verify that the grantee has procedures and processes in place i 44 CFR 1340(3) i 1 to monitor grant and sub-grant supported activities to assure compliance with 44 CFR 1326 i applicable Federal requirements and that performance goals are being achieved OMB Circular A- a sub-recipient monitoring plan). 133 has a written internal protocol in place to monitor sub-grantees that receive sub-grants for EMPG, PDM, ONA, PA, HM grant programs. The procedures identify a process for desk review and site visit monitoring. There is a standard protocol that is used to record information for each grant awarded to a sub-recipient, as well as a Monitoring Memorandum which compiles the results of the review. The Site Visit Protocol Procedures document is attached as Appendix B. I Comments: i EMPG - has been unable to conduct any site visits or desk reviews of sub-recipients during FY 2013 due to staff shortages. A sample desk review monitoring memorandum from Fiscal Year 2012 dated June 14 2012 is attached as Appendix 0. Public Assistance has been unable to conduct site visits andior desk reviews due to inadequate staffing. The lack of adequate sub-recipient monitoring for Public Assistance sub-recipients has been a repeat A-133 audit finding. With the implementation of the most recent CAP on June 28, 2013, FEMA is hopeful that sub- recipient monitoring for Public Assistance grantees will improve and there will no longer be audit findings. HMGP FEMA believes that conducts adequate sub-recipient monitoring of Hazard Mitigation (disaster) sub-grantees. Mitigation Grantees Non Disaster Visits to sub-grantees are conducted periodically for recipients of Pro-Disaster Mitigation Grant Programs. if a site visit has been conducted, in lieu of a format monitoring report; the results of the site visit inspection are captured on the quarterly progress report. i Records Retention. Verify that grantee has policies. procedures. or schedules in place 44 CFR 13.42 to maintain all records required by 44 CFR 13.42 for the specified time period. Department of Homeland Security Federal Emergency Management Agency Monitoring Protocol 1 [Comments Grantee retention policy is greater than the federal regulations for records retention. ?Alliste- it . _?uidance Source TDocumenratlon Supporting Salaries and Wages. Verify that the grantee maintains 2 CFR 225 App B. appropriate source documentation for salaries and wages. 8(h) Comments: i Verified. staff complete bi~wee kly timesheet for time spent on different projects, and the supervisors review and approve the timesheets to ensure accuracy and allocabllity to particular projects. i_ For States: Written Travel Policy. Verify that the grantee has a written travel policy in placeabsence of an acceptable, written governmental unit policy regarding travel costs, the . 43 . grantee must comply with the lodging and subsistence limits outlined by Chapter 57 of I Title 5, or GSA per diem amounts. 1 Comments: abides by the State's policy on travel. This policy governs state employees who are conducting in-state, out-of?state. and international business travel with the State of West Virginia. The policy can be I found at: i 1' I Closeout. Verify that the grantee has submitted or plans to submit all financial, 1. i 1 3. performance, and other required reports to FEMA within 90 days of expiration or i 2 CFR 215.71 termination of date. 1 i Comments: it is policy to submit all required reports within 90 days of expiration of award. .Americ?n Researcsand?sgeierv .- 4 Reporting. Verify that the grantee has fully satis?ed all quarterly reporting ARRA Section requirements on time. i 1512 Comments: I has not been awarded ARRA grants. 5 Purchasing. Verify that all grantee purchases satis?ed the required use of American 5 ARRA Section iron, Steel, and Manufactured Goods? 1605 Comments: Not Applicable Wage Rates. Verify that grantee has satis?ed Wage Rate requirements. ARRA Section . 1606 Comments: Not Applicable Z- . . FATA or I Prime Eyeculive Compensation Reporting. Review the expiration date of the grantee?s Transparency Act 7 Central Contractor Registration (COR) to verify active registration. Also, cross - FLAGS-282, as i reference the grantee?s with the grant application, these numbers must be the amended by same. section 8202(a) of P.L. 110-252 10 Department of Homeland Security Federal Emergency Management Agency Monitoring Protocol Comments: is not in compliance with FFATA requirements. DHSEM staff was not aware of the Federal Funding Accountability and Transparency Act (FFATA) sub-recipient reporting requirements. The website was provided and staff was advised that reporting of sub-recipient awards of $25,000 or more dating back to October of 2010 is a requirement. FFATA or Transparency Act Prime Executive Compensation Reporting. If the grantee is required to report PL mgaezl as 8. executive compensation, verify that reporting was conducted by the end of the month, i . . amended by i followrng the month the award or obligation was made. section 6202(3) of P.L. 110-252 1 Comments: Not required i FFATA or i Sub?Award Reportino. Verify that the grantee has reported all required actions in the Transparency Act I 9 FFATA Sub~award Reporting System (FSRS) within the required timeframe for sub- - P.L.109-282. as i awards, The prime grantee must report ail sub?awards over $25,000 by the end of the amended by month, following the month the sub-award or obligation was made. section 6202(a) of i PL. 110-252 I Comments: Not in compliance. has not been reporting sub-awards over $25,000 as required by the FFATA Act. 1 I Sub?Award Repor?q. Verify that the grantee has reported ail required actions in the ifa?g?o?aignc Act?i FFATA Sub-award Reporting System (FSRS) within the required timeframe for sub- $0948; as 10. awards. if the prime grantee is required to report the Executive Compensation for a am'e?ded i sub-award. they must do so by the end of the month following the month the award or section 6202(3) of i obligation was made. 1, PL ?0252 i i Comments: Not required. Section Expenditure Review Grantee Questioned-CoSts General Ledger Identification (Documentiwarrant number, etc.) Reason Questioned Cost Description Amount 2 No questioned costs. Drawdown requests were reviewed and sources documentation provided to verify that they were incurred within the period of performance and was appropriate to the project. b?n-n-r- . . Appendix Appendix A Self-Certification Document Appendix Sub-recipient Monitoring Protocol (same format 11 Department of Homeiand Security Federal Emergency Management Agency Monitoring Protocol Appendix Appendix Appendix used for Site Visits and Desk Reviews) EMPG Sub-Recipient Monitoring Report dated June 14, 2012 FEMA, Region CAP monitoring plan for FEMA, Region Programmatic Monitoring Report for Emergency Management Performance Grant Programs. 12 - gain-U Grantee Deport- II 2010-EP-E0-0036A- I EMW-ZOIZ-EP-OODBQ Question: I I Question 198 Date Site Visit process initiated December 12, 2012 '199 Date Site Visit began June 25, 2013 205' representatives). include their role/title and email address. Tommy Dingess EM PG POC Please list who you met with during the Site Visit process grantee and sub grantee 202' I planning documents) and document in the Issue Log as an open issue. Yes Did the grantee satisfy all requests for additional information during the Site Visit process? if i no, please briefly describe the missing information in the Notes field MOUs, charters, i201 Review open issues documented in the issue Log and select a few to address through the Desk Review process (max. ten). in the response field, please list the selected issues. and the Yes open issue. Yes. The only items lacking were documented current subgrantee monitoring. Does the grantee align operations and emergency management planning activities to NIMS Does the grantee maintain well-documented grant records, which contain both the signed I award document and current correspondence with the appropriate FEMA Analyst GPD Program Analyst, FEMA Regional Anaiyst)? if no, piease document in the Issue Log as an i r'ante'eipirogrammiagic'site .Mdnitdiringi??port?f We?ll?: Question.204 is the grantee able to provide evidence of an active sub grantee monitoring process He, files i are current, well-maintained, and include documentation of issues identified through I monitoring)? if yes, brie?y describe the evidence reviewed in the notes ?eld. if no, please .- explain and document as an open issue in the issue Log. i Previous subgrantee monitoring had shown to be successful at resolving issues. However, the I grantee failed to verify that subgrantee monitoring occurred during the current Federal FY. EDue to DR Activity and staff shortages ail monitoring activities have been placed on hold. 305 211 is there evidence of a process for documenting issues found through the sub grantee 1 monitoring process and following up until the issue is resolved? 1 Previous subgrantee monitoring had shown to be successful at resolving issues. However, the i rgrantee failed to verify that su bgra ntee monitoring occurred during the current Federal FY. EDue to DR Activity and staff shortages ail monitoring activities have been placed on hold. i if the grantee has purchased equipment in the prior fiscal year, do they have suf?cient equipment management processes and procedures in place to certify that the equipment has}. been procured and managed in compliance with the requirements in 44 CFR Part 13 and 2 CFR Part 215? Please select a few equipment purchases, at random, to discuss with the grantee when responding to this questFon and briefly summarize them in the Notes field. Yes. The grantee shared with me their inventory plan Briefly describe any concerns or issues raised by the grantee during the Site Visit. The grantee failed to verify that subgrantee monitoring occurred during the current Federal i FY. Due to DR Activity and staff shortages all monitoring activities have been placed on hold. 1 Briefly describe any requests for training or technical assistance that were raised during the Site Visit. FEMA recommends during the next Tech visit to accompany the grantee on a monitoring 'Gra?nt?i Programinatli: Site Moni't'b'ri'ng-Rebori' I 2010-EP-E0-0036A 5 g? Question} Question ff: j. . . visit. 208' Date Site Visit iiompie?ted grantee noti?ed of findings) June 26, 2013 i