HMEP States-Territories NOFO Questions and Responses 04.17.19.docx

HMEP States and Territories Questions Received

1. Is food or refreshments allowable?

Food or refreshments are generally unallowable under PHMSA’s Hazmat Grants Program. PHMSA encourages applicants to plan sufficient meal breaks and use per diem rates for conference attendees to purchase their own food. However, beverages such as water for trainings that are in rural locations or training conducted outside where hydration is needed to ensure exercises are safely conducted. If an applicant has a unique circumstance that may require food, the request to incur food cost should be requested and explained in the application.

2. Is Tier II software an eligible expense for state agencies and local agencies?

Response: For Tier II software to be an eligible expense, applicants must explain how it supports hazmat planning needs such as using the data made available through the software to update plans, conduct commodity flow studies, and identify specific chemicals being transported and stored within local communities.

3. Is the period of performance 2 years or 3 years? The HMEP NOFO references 2019-2021.

Response: The period of performance for states and territories is 3-years, 2019-2022. The reference to 2019-2021 is an error and the NOFO will be updated to correct the performance period. Please submit activities for three years if you are a designated HMEP state agency.

4. Why is food listed as an unallowable cost in the HMEP expenditures guide for conferences? Per 2 CFR 200 432, a conference is defined as a meeting, retreat, seminar, symposium, workshop or event whose primary purpose is the dissemination of technical information beyond the non-Federal entity and is necessary and reasonable for successful performance under the Federal award. Allowable conference costs paid by the non-Federal entity as a sponsor or host of the conference may include rental of facilities, speakers' fees, costs of meals and refreshments, local transportation, and other items incidental to such conferences unless further restricted by the terms and conditions of the Federal award. As needed, the costs of identifying, but not providing, locally available dependent-care resources are allowable. Conference hosts/sponsors must exercise discretion and judgment in ensuring that conference costs are appropriate, necessary and managed in a manner that minimizes costs to the Federal award. The Federal awarding agency may authorize exceptions where appropriate for programs including Indian tribes, children, and the elderly.

Response: 2 CFR 200.432 allows the non-federal entity to pay for food, not the federal agency.

Allowable conference costs paid by the non-Federal entity as a sponsor or host of the conference may include rental of facilities, speakers' fees, costs of meals and refreshments.

2 CFR 200.432 does give the agency the authority to allow food at conferences if it is deemed reasonable and necessary. In general, PHMSA encourages applicants to plan sufficient meal breaks and use per diem rates for conference attendees to purchase their own food.

5. We have three or four HMEP funded LEPC projects on the agenda. We don’t send LEPCs money directly as a sub-award. Should these projects be identified on the application under #4 LEPCs Sub-Awards Information or under our Planning activities?

Response: If the applicant is expending the funds on behalf of the LEPCs it should not go under #4 sub-grantee activity information of the HMEP application form. The applicant should identify the activity in #3 under grantee activity information of the application form.

6. We sometimes approve specialized field training (i.e., HazmatIQ or PropaneIQ) for our active LEPCs. Should they be included in our Grantee Activity Information under Activities Supporting Program Goals or included in the next section for LEPCs Sub-Awards Information?

Response: If the applicant is providing the specialized field trainings for the LEPCs then they should list the activities in #3 Grantee Activity Information; however if the applicant is providing the funding to the LEPCs by way of a subaward then the specialized field activities should be listed under #4 subgrantee activity information.

7. We are ready to move forward with our commodity flow study. The project is expected to span three years. Should we list the amount of funding requested as Planning in the Grantee Activity Information section?

Response: Yes, the commodity flow study is a planning activity under the HMEP grant. The applicant should break out the expected cost for each year.

8. I just submitted the SF-424 to grants.gov, after I was done I looked at the printed form and found out on #7 d, I think I erroneously hit the incorrect state? Will this matter? How will I be able to correct it?

Response: If an applicant is aware of any errors in their application package to include Federal standard forms, you should contact the grants.gov helpdesk to see if they can pull your submission so you may make edits. If grants.gov is unable to retrieve you submission you can submit another application with the revisions. PHMSA will review the latest application submitted by the applicant.