*What are Force Account Labor hours?
In declared disasters, FEMA may reimburse for the straight-time and overtime of emergency personnel performing disaster-related activities that take them away from their normal jobs. For example, public works staff may be required to perform debris removal, which is not part of their daily responsibilities. Police and fire overtime to respond to disaster-related emergency situations may also be eligible for reimbursement. In some cases, needed equipment such as chain saws, sandbags, and other tools have costs that may also be reimbursable.
It’s also important that you have a current overtime plan in place before a storm hits. FEMA will reimburse overtime based on the adopted plan in place at the time of the disaster.
Working with FEMA will take staff resources away from their normal duties. Many state and local officials hire supplemental resources so that they can continue daily operations and have the capacity for regular interactions with FEMA. While there are upfront costs, a strong and reputable consultant ensures that every interaction with FEMA is documented and is therefore reimbursable as part of the project.
Contract disaster recovery work wisely
A key component to working with FEMA is being able to efficiently and effectively deploy the right staff at the right time. State and local governments may not be well-versed in doing disaster recovery work on a regular basis. There are training programs available online from FEMA’s Emergency Management Institute on topics such as public assistance, debris removal, and long-term redevelopment.
While we encourage you to do as much training as possible, it’s not always practical. That’s why we recommend that you seek out the support of experts who can help you via contingency contracts. You can—and should—pre-bid standby contracts for some of the work. You won’t scramble as much after a disaster if you’ve already pre-competed certain contracts ahead of time.
However, you MUST competitively award contracts, as sole source contracts will not be approved. Remember that all levels of government need to follow the federal acquisition regulations (FAR) for the RFP and bid processes by getting three bids for repair and restoration work.
Tip: Follow the FAR. If you don’t, FEMA can either deny the money or the Auditor General or GAO can come back during the auditing process and take back the assistance.
How to vet your contractors
When you evaluate contractor proposals, it’s important to understand how well they performed on prior jobs, and whether the people being presented actually work for the company. Many contractors are temporary employees who may work for several companies, so you want to be sure that you will get the experts promised to you during the proposal phase.
Talk to the references provided and ask questions such as:
- Did the company perform well?
- Were they engaged and available?
- Did you get the people you expected to get?
- How much did they turn over personnel in the course of the job?
- Were they of the quality that they were purported to have based on the way their resumes were presented?
- Did they match the criteria that you asked for?
- Have they done this before, and can they provide me with evidence?
Of course, proposals can only be as strong as the requirements you set forth. Have a thorough understanding of the work you’re asking contractors to do—and be as specific as possible when creating your RFP. For example, do your contractors need to interface directly with the U.S. Army Corps of Engineers? Then be sure to state that need in your project requirements.
It’s also important to have a strong and defensible scoring system when evaluating contractor proposals. Your criteria will help you determine who is merely answering the questions and who is actually offering you real advantages. Services with flashy names are much less helpful after a disaster than those with demonstrated on-the-ground experience. Remember that the flashy name likely won’t be working on your project.
Local governments should plan for interactions with state and FEMA officials
Local governments usually conduct disaster assessments jointly with state and FEMA officials. Do you have a game plan for how your initial interactions will take place? Have you planned out where you’re going to have FEMA brief your various government agencies?
You want to make sure you’re thinking in advance about where that briefing will be, how you will manage it, and who will need to be invited. When you bring these groups together, everyone will have just been through a significant event. They will likely be frightened and anxious to move forward.
There will also be a sizable amount of political pressure—legislators, county councils, and others who will be pushing to get the ball rolling. It’s important to have a good public affairs plan in place. You’re going to get a lot of press interest in the status of the recovery efforts. Having a regularly updated list of press contacts at your local media outlets and state agencies can save you time following a disaster.
Tip: FEMA’s Emergency Management Institute (EMI) can help you on the public affairs front. It has programs for basic and advanced public information officers and online resources that can prepare you for media interaction. You will need to be savvy about the best ways to inform the public about disaster relief and recovery efforts, and EMI provides a solid foundation.
Figure out your state’s federal match requirement
Do you know how your state handles FEMA’s requirement for a non-federal match for aid? In some cases, the state will pay the standard 25% non-federal costs. In others, the state will split those costs with the local governments. Some states require that the locals pay it all.
States may choose to make a determination during the disaster—they are not bound by language in the federal legislation. The federal law only specifies that there is a non-federal share, and that it must be matched by some entity (state or local). Each governor is granted the authority to make the exact match determination. Make sure you have the most up-to-date information to allow your governor or state government the ability to make a judgement call in the moment.
In North Carolina, for example, the state traditionally covers the non-federal match with state- appropriated funding. In Pennsylvania, there’s traditionally been a split of the share between the state and local governments with the state being responsible for the larger piece of the costs. In a few states, the requirement is entirely local.
Tip: Local governments should check with their State Emergency Management Office to determine if their share of the non-federal costs is specified in state statute, or if their state allows the governor to decide the financial split after each disaster.
Create an audit trail for disaster management costs
To adhere to FEMA’s public assistance program, you need to (1) document the damage; (2) determine how much it’s going to cost to replace/rebuild; and (3) have an audit trail. The importance of having a detailed, complete, and accurate audit trail cannot be overstated. You need to know what money is being used for what purpose, and whether the match requirements are being properly applied to the project.
You should be thinking about your non-federal match requirements in advance. When it comes to the match, what moneys are you going to use? Are you going to use Community Development Block Grant (CDBG) money that you received to match the FEMA money? Make sure you document this and cross-reference it against the requirements of the FEMA public assistance program to ensure your plan meets the stated requirements. If you’re using CBDG money to satisfy FEMA, you will also need to make sure that you’re using the money in a way that won’t get you in trouble with HUD.
FEMA’s pre-disaster recovery planning guide for local governments: Everything (else) you need to know
Our tips are meant to give you a quick and digestible way to make sure you’re covering your bases throughout the planning process. But when you need to dig deeper, FEMA has you covered with a comprehensive guide for local governments. This guide walks you through pre-disaster planning, from plan development to plan implementation and maintenance. There’s even a pre-disaster recovery planning key activities checklist that serves as a handy reference as you go through the process.
You’re not alone
Without a doubt, this work is hard and stressful. But every interaction you have with FEMA—and there will be many—has the potential to move you closer to recovery if you follow the tips outlined above. The process can feel overwhelming, but you’re not alone. ICF has a deep bench of disaster management experts who can help you prepare for natural disasters, mitigate risk, and maximize your recovery dollars. We’ve done it for Katrina, Sandy, Harvey, Maria, and Irma, and we can do it for you.