Why it’s important to adopt a “closeout mentality” for FEMA grants
City, county, and state level emergency managers are crucially important figures when a disaster strikes and in dealing with the aftermath. But it’s what they may or may not be doing before a disaster that could make all the difference in terms of getting timely reimbursement from FEMA.
We sat down with Al Blankenship, vice president of disaster management at ICF—whose expertise spans over 15 years in housing and mitigation programs, implementation and closeout of resettlement programs, and grant management contracts—to discuss the importance of the closeout mentality. This interview has been edited and condensed for clarity.
Q: Let’s start with the basics: What do you mean by the “closeout mentality”?
In order to close a disaster recovery grant out, you have to have done everything in compliance with regulations from day one. In fact, FEMA can de-obligate the money for your projects if things weren’t done correctly from the start. The typical emergency management mentality is to worry about the closeout process later—after all, it happens many years down the line after the hurricane, flood, earthquake, or other catastrophic event. But that starts the entire process off on the wrong foot.
Embracing the closeout mentality is all about making a few small changes and additions up front that can save you weeks or even months on the back end. The closeout process is where the final checks are done to make sure everything is documented and filed correctly, and that all regulations—such as procurement—were followed. You can’t (easily) go back and retroactively fix your mistakes, so knowing and understanding up front what steps you need to take to close your grant will save you a lot of grief.
Q: What’s the biggest stumbling block for subrecipients when it comes to the closeout process?
Procurement, hands down. In the heat of the moment, subrecipients have a tendency to procure services incorrectly. That includes actions like not getting the correct type and number of bids before hiring a contractor. Don’t fall in the trap of sole-sourcing in an emergency. If FEMA concludes procurement regulations weren’t met, they won’t reimburse that spending and the funds will have to come out of your coffers.
Q: Can you elaborate on the importance of pre-disaster preparation to avoid problems?
Lack of preparatory work is the biggest hindrance that emergency managers face. There’s a lot that grant subrecipients can and should do to have pre-positioned contracts in place that meet the conditions of the FEMA procurement process. The Sandy Recovery Improvement Act smoothes the process by authorizing the use of estimates for debris removal, which is a key aspect of many disaster recovery projects. Frankly, it’s human nature for emergency managers to focus on the short-term requirements in the immediate response to the disaster. You’re literally in the midst of a crisis and the desire is to fix things fast. But it’s important to always remember that disaster recovery is a long-term process. It may sound counterintuitive, but being prepared for the final closeout of your FEMA grant is the most important first step.
Q: What can emergency managers do to make the process smoother?
Before a disaster strikes, subrecipients need to be trained on how to do everything correctly. That training will make it more likely that they won’t make bad decisions during a crisis. If you know what success looks like from managing previous disasters, then create a checklist or other type of workflow document and use it from the beginning. That’s what adopting the closeout mentality is all about.
FEMA is now moving toward a “verify as you go” process. This requires the grant manager to assess eligibility by determining if what has been done to date by subrecipients is in compliance. The good news here is that this could help spot problems and allow them to be fixed sooner, rather than at the very end of the grant.
A huge challenge for many subrecipients is the loss of continuity and institutional memory when staff members change. While it makes sense to assign responsibility to someone that you anticipate will be there long-term, things happen. Preparation is key for ensuring a better staff transition. If you’ve created that checklist or workflow, make sure that multiple staff members know where it is and how to use it.
Regional management officials need to emphasize the need for timely closeouts of disasters. Delays in closing disasters start at the grantee level and continue through final processing at agency headquarters.
Q: Is anyone doing this well?
Many states could take a page from Louisiana’s book. Their state emergency managers do an annual “road show” with emergency managers from cities and counties that covers a variety of topics on training and technical assistance. They also create instructional and procedural manuals so that their subrecipients can be better prepared to manage future disasters. Again, that pre-disaster work is what I call the closeout mentality.