Sneak Preview: FEMA Provides Guidance on Hardship Waivers

March 29, 2018 | By Jerry Ashworth | Post a Comment

xgran_bookshot(The following was excerpted from a recent article in the Federal Grants Management Handbook.) The Federal Emergency Management Agency (FEMA) recently issued guidance outlining the minimum requirements for requesting economic hardship waivers for applicants and recipients of Assistance to Firefighters (AFG), Fire Prevention and Safety (FP&S) and Staffing for Adequate Fire and Emergency Response (SAFER) grant awards beginning with the federal fiscal year (FY) 2017 grant cycle.

Such waivers would include reductions of the nonfederal cost share requirement (§200.306), maintenance of effort requirement (15 U.S.C. §2229(k)(3)), minimum budget requirement, non-supplanting requirement, or any combination of these, based on demonstrated economic hardship. Under the minimum budget requirement, a SAFER recipient’s budget for fire-related programs and emergency response must not be below 80 percent of the recipient’s average funding level. Under the non-supplanting requirement, funds received under a SAFER grant may not be used to replace funds that would be available from state or local sources or from the Bureau of Indian Affairs.

To be eligible for an economic hardship waiver, recipients under these programs must affirm that its governing agency or municipality does not have the available financial resources to cover all or part of the cost share, maintenance of effort, minimum budget requirements or the restriction on supplanting. Recipients also must affirm that they do not have access to financial resources from any source that could cover these costs, including monies from reserve funds, savings accounts, rainy day funds or other financial instruments.

In addition, a recipient must demonstrate economic hardship in one of two ways. One way is to show that the following conditions exist: (1) the rate of unemployment in the recipient’s community has had a net increase of no less than 10 percent over the last three years preceding the application for the waiver; (2) the community’s unemployment rate has exceeded the annual national average rate of unemployment for three of the last five years; (3) the community’s median household income over the last three years for the recipient’s community has been 80 percent or less than that of the median household income in the state in which the recipient is located; (4) the Social Vulnerability Index in the recipient’s community is greater than or equal to the 75th percentile for the nation; or (5) the recipient has filed for bankruptcy within the previous three years.

A second method for demonstrating economic hardship would be to provide a narrative response to demonstrate such conditions, including the history of the hardship, measures the entity has taken to obtain other funding and how the lack of obtaining a waiver would impact the entity’s ability to accomplish its mission.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site.)

As a reminder, we have all of our Federal Funding Training Forums scheduled for 2018. Please let me know if you have questions or can make any of these. We hope to see you there!

  • Monday April 16 – Wednesday April 18 in WASHINGTON, D.C.

http://www.federalgrantsforum.com/dc/index.html?src=JMR

  • Wednesday May 1 – Friday May 4 in ST LOUIS

http://www.federalgrantsforum.com/stlouis/index.html?src=AT

  • Wednesday July 25 – Friday July 27 in MINNEAPOLIS

http://www.federalgrantsforum.com/minneapolis/index.html?src=AT

  • Wednesday October 17 – Friday October 19 in ATLANTA

http://www.federalgrantsforum.com/atlanta/index.html?src=AT

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