FEMA provides regular updates on the Assistance to Firefighters Grant Program, or AFGP. Keep up with the latest about America’s largest fire grants by checking out this update from August 2022:
Fire grant news from FEMA
The Assistance to Firefighters Grant Program is pleased to provide this update for August 2022. Each month, we supply information relative to the management of current grants, as well as helpful details on upcoming grant opportunities.
August 2022 update
- Approval of General Applicability Waiver of the Build America, Buy America Act (BABAA) Requirements
- FY 2021 AFG Programs Status Update
- Sam.gov Entity Validation Delays
- Grant Management Training – Cost Considerations
- Federal Financial Reports (SF-425)
- AFGP Success Stories
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Build America, Buy America Act
Approved General Applicability Public Interest Waiver
The Office of Management and Budget approved FEMA’s General Applicability Public Interest Waiver of the Build America, Buy America Act (BABAA) requirements on July 1, 2022. The waiver will be effective for six months.
For FEMA grant awards, and any other funding FEMA obligates through Jan, 1, 2023, recipients and subrecipients will not be required to follow the BABAA requirements.
For FEMA programs subject to the BABAA requirements, for any new awards FEMA makes after January 1, 2023, as well as new funding FEMA obligates to existing awards or through renewal awards where the new funding is obligated after January 1, 2023, recipients and subrecipients will be required to follow the BABAA requirements unless another waiver is requested and approved.
SAM.gov Entity Validation Delays
On April 4, 2022, the federal government changed entity validation service providers and began using the Unique Entity ID in SAM.gov to uniquely identify entities. All entities, even those already registered in SAM.gov, must validate their entity information through the new service provider. Data rights limitations require SAM.gov to collect the data from the user directly, not use previously validated data. This means entities may have to provide supporting documentation to update the new service provider’s data. This is an expected part of a complex data transition.
- The Unique Entity ID is a 12-character alphanumeric ID assigned to an entity by SAM.gov.
- As part of this transition, the DUNS Number has been removed from SAM.gov.
- Entity registration, searching, and data entry in SAM.gov now require use of the new Unique Entity ID.
- Existing registered entities can find their Unique Entity ID by following the steps here.
- New entities can get their Unique Entity ID at SAM.gov and, if required, complete an entity registration.
Due to high demand, entity legal business name and address validation tickets are taking longer than expected to process.
SAM.gov is working on tickets in the order received. You can find resources related to this process here. Please do not create multiple incidents for the same request.
FY 2021 AFG Programs Status Update
FY 21 AFGP award announcements are underway. Awards will continue to be made over the next several weeks until the funds are exhausted. As award determinations are finalized, notification will be sent to grant recipients. Award information will also be posted on the FEMA website as each round is announced
AFG Award Listings: Assistance to Firefighters Grants | FEMA.gov
SAFER Award Listings: Staffing For Adequate Fire and Emergency Response (SAFER) | FEMA.gov
FP&S Award Listings: Fire Prevention and Safety | FEMA.gov
Grants Management Training
Cost Principles
Federal regulations provide guidance on basic considerations when determining whether a cost associated with a grant is eligible. In the case of the Assistance to Firefighters Grant, 2 CFR Part 200 provides this guidance beginning at § 200.403. Application reviewer will examine budgets submitted for projects using this guidance to determine whether the costs are allowable, allocable, reasonable and necessary. Keep these cost principles in mind when developing budgets for applications or submitting amendments to revise a budget or change the scope of a project. These cost related factors are considered during the review in each of these situations. Below is an explanation of each cost consideration directly from the regulation.
200.403 Factors affecting allowability of costs.
Except where otherwise authorized by statute, costs must meet the following general criteria to be allowable under federal awards:
(a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles, except for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also § 200.306(b).
(g) Be adequately documented. See also §§ 200.300 through 200.309 of this part.
(h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3).
200.404 Reasonable costs.
A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-federal entity is predominantly federally funded. In determining reasonableness of a given cost, consideration must be given to:
(a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-federal entity or the proper and efficient performance of the federal award.
(b) The restraints or requirements imposed by such factors as: sound business practices; arm’s-length bargaining; federal, state, local, tribal and other laws and regulations; and terms and conditions of the award.
(c) Market prices for comparable goods or services for the geographic area.
(d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-federal entity, its employees, where applicable its students or membership, the public at large, and the federal government.
(e) Whether the non-federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the award’s cost.
200.405 Allocable costs.
(a) A cost is allocable to a particular federal award or other cost objective if the goods or services involved are chargeable or assignable to that federal award or cost objective in accordance with relative benefits received. This standard is met if the cost:
(1) Is incurred specifically for the federal award.
(2) Benefits both the federal award and other work of the non-federal entity and can be distributed in proportions that may be approximated using reasonable methods; and
(3) Is necessary to the overall operation of the non-federal entity and is assignable in part to the Federal award in accordance with the principles in this subpart.
(b) All activities which benefit from the non-federal entity’s indirect (F&A) cost, including unallowable activities and donated services by the non-federal entity or third parties, will receive an appropriate allocation of indirect costs.
(c) Any cost allocable to a particular federal award under the principles provided for in this part may not be charged to other Federal awards to overcome fund deficiencies, to avoid restrictions imposed by federal statutes, regulations or terms and conditions of the federal awards, or for other reasons. However, this prohibition would not preclude the non-federal entity from shifting costs that are allowable under two or more federal awards in accordance with existing federal statutes, regulations or the terms and conditions of the federal awards.
(d) Direct cost allocation principles: If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (c) of this section, the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Where the purchase of equipment or other capital asset is specifically authorized under a federal award, the costs are assignable to the Federal award regardless of the use that may be made of the equipment or other capital asset involved when no longer needed for the purpose for which it was originally required. See also §§ 200.310 through 200.316 and 200.439.
(e) If the contract is subject to CAS, costs must be allocated to the contract pursuant to the Cost Accounting Standards. To the extent that CAS is applicable, the allocation of costs in accordance with CAS takes precedence over the allocation provisions in this part.
Federal Financial Report (SF-425) is due
This is a reminder that you must submit your Federal Financial Report (SF-425) for Fiscal Year (FY) 2019 and 2020 Assistance to Firefighters Grants no later than July 30, 2022. This report includes all financial activity from the start of the period of performance up to June 30, 2022.You are required to complete this report even if no funds have been expended during the reporting period.To complete your Federal Financial Report (SF-425), please log in to FEMA GO and navigate to your grant.For more information, review the Federal Financial Report instructions or visit FEMA.gov for Frequently asked questions. For further questions or assistance, contact the AFG Helpdesk toll-free at 1-866-274-0960 or email [email protected]