HMIT NOFO Questions and Responses_06May19.docx

HMIT Questions Received

1. We are a state agency. Are we eligible to apply for this grant?

Response: No. In accordance with Title 49 U.S.C. 5107, the HMIT grant program is open to nonprofit organization that demonstrates—

(A) expertise in conducting a training program for hazmat employees; and

(B) the ability to reach and involve in a training program a target population of hazmat employees.

2. Is food or refreshments allowable?

Response: Food or refreshments are generally unallowable under PHMSA’s Hazmat Grants Program. PHMSA encourages applicants/grantees to plan sufficient meal breaks and the use approved per diem rates to allow conference attendees to purchase their own food. If an applicant has a unique circumstance that may require food or drink (e.g., remote location, outdoor training, etc.), the request to incur food cost should be included and explained in the application.

3. Why is food listed as an unallowable cost in the HMEP expenditures guide for conferences?

Response: 2 CFR 200.432 gives the agency authority to allow grantees to provide food at conferences. However, it also allows the Federal awarding agency the flexibility to restrict these costs in the terms and conditions of its grant awards. Due to limited grant funds, PHMSA has chosen not to allow food costs. PHMSA encourages grantees to plan sufficient meal breaks and the use of approved per diem rates to allow conference attendees to purchase their own food.

4. Will PHMSA award a grant to an applicant who is requesting an amount lower than the award floor of $250,000?

Response: Yes, an applicant can request an amount lower than the award floor of $250,000.

5. Is the goal to train instructors to train employees in their workforce, train individuals to become independent trainers, or both??

Response: The goal of the HMIT grant program is to train instructors to train hazmat employees on the requirements of the Hazardous Materials Regulations (HMR), Title 49 CFR Chapter I, Subchapter C. The intent is not to train individuals to become independent trainers.

6. Where is the train-the trainer model located that is referred to in the Programmatic Evaluation section, page 13 or 17, item #h??

Response: PHMSA does not provide a train-the-trainer model for applicants. The applicant is to provide an outline or description of their curriculum that reflects a train-the-trainer concept in accordance with the requirements under Hazardous Material Regulations (HMR).Question #h “Does the application follow the train-the-trainer model, as listed as a priority in the funding announcement?”, is asking if the applicant has complied with the intent of the HMIT grant program.

7. Are there restrictions regarding what parts or how much of the program a subgrantee can perform on behafe of a grantee?

Response: No. PHMSA does not place restrictions on what parts and how much of the program a subgrantee can perform on behafe of a grantee.

8. The FY 2019 HMIT NOFO references the 2 CFR 200.70 definition of Non-profit organizations in section C.1, Eligible Applicants, but does not state the following language contained in 2 CFR 200.70 “…. not including IHEs…” Are we eligible to apply for the HMIT grantee?

Response: The “…not including IHEs…” language was inadvertently omitted from the reference to 2 CFR 200.70 in the Eligibility section of the NOFO, but is expressly included in the regulation itself. 2 CFR 200.70 defines a Non-profit organization as “corporation, trust, association, cooperative, or other organization, not including IHEs, that: (a) Is operated primarily for scientific, educational, service, charitable, or similar purposes in the public interest; (b) Is not organized primarily for profit; and (c) Uses net proceeds to maintain, improve, or expand the operations of the organization.

Therefore, if a potential applicant meets the definition of a non-profit set forth in 2 CFR 200.70, and is NOT a part of an Institution of Higher Education (IHE), it is eligible for an HMIT grant award.