What can federal aid recipients do to prevent this situation from happening? Here are four keys to managing multiple legacy disasters while also responding to an active disaster.
1. Assign those with experience to close out legacy projects.
Take advantage of the expertise of staff who’ve previously managed grants to completion by assigning them to help close legacy projects. A percentage of the total dollars from disaster funds is allocated for management costs and is disbursed during the life of the disaster. Funding should be managed to ensure sufficient funds for closeout implementation are available. Capitalizing on the experience of private sector contractors with grants management expertise can also help ensure sufficient experienced staffing to complete the closeout cycle without straining resources assigned to current disasters.
2. Render decisions based on final deadlines.
When necessary, establish a firm deadline for all subrecipients. Historically, subrecipients have been afforded deadlines to comply with submission of documentation. The decision to terminate the opportunity to submit documentation will no doubt cause some subrecipients to have disbursements deobligated. However, in most cases, failure to produce compliant and adequate documentation during the lifecycle of a disaster indicates the inability to produce this documentation at closeout.
Education and documentation are key to keeping subrecipients on track. Start by helping them understand what's allowed and what's needed (e.g. grantees can provide technical assistance to subrecipients but cannot do the work for them). Detail discrepancies and omissions using checklists and reports, as these documents are particularly useful for recipients providing technical assistance. And finally, conduct ongoing outreach and education to subrecipients—this real-time dialogue is critical to achieving closeout. With final deadlines in place, recipients will be better able to focus their resources and efforts on concluding the closeout process.
3. Pay attention to details to manage grants properly.
Adopt a closeout mentality from the beginning in order to set up maximum funding distribution and minimum likelihood of deobligation. The reality is that during the emergency and recovery period, closeout is often not top of mind. Consequently, as closeout occurs, recipients will make multiple requests to subrecipients for documentation, which in some cases cannot be provided. Providing technical support at the onset of a disaster—by focusing on compliance and completeness of documentation—will expedite the closeout process. At some point, grantees will have to decide to go with what documentation is available and to acknowledge that some portion of the grant may be deobligated. The grantee must inform the subrecipient of this situation.
4. Choose a strategy that matches the event.
Understand that the strategy for implementing a current disaster is different from closing out legacy disasters. For legacy projects, FEMA will negotiate to develop an agreed-upon plan that focuses primarily on validation of funding that was expended. Recipients can collaborate with FEMA on possible concessions for alternative solutions to documentation requirements. For a current or future disaster, there are prescribed requirements for completion and compliance that require verification throughout the implementation process. One successful strategy for arriving at the closeout cycle is to focus on achieving fully-compliant documentation as disaster recovery is implemented.
If you are facing a looming threat of new disasters on top of your current load, planning and training will be essential to successful implementation. The work must continue on legacy disasters throughout the challenge of managing additional disasters. Approaching future disasters with a closeout mentality—combined with a continuous dedication to legacy closeout—will ensure the maximum amount of federal assistance through disaster recovery.