PHMSA-HMEP-Grant-Guide.pdf

HAZARDOUS MATERIALS EMERGENCY PREPAREDNESS GRANT GUIDANCE

HAZARDOUS

MATERIALS

EMERGENCY

PREPAREDNESS

GRANT GUIDE

Catalog of Federal Domestic Assistance Program No. 20.703

Table of Contents I. Introduction II. HMEP Grant Overview III. Expenditure Guidelines

4.2 Allowable Planning and Preparedness Activities

4.3 Allowable Training Courses

4.5 Allowable Equipment, Supplies, and Materials

4.5 Conditionally Allowable Expenditures

4.5.1 Costs Requiring Prior Approval

4.6 Unallowable Expenditures

IV. Grant Lifecycle

5.1 Pre-Award Phase

5.1.1 Planning an Opportunity

5.1.2 Announcing an Opportunity

5.1.3 Searching for Opportunities

5.1.4 Registering on Grants.gov

5.1.5 Completing an Application

5.1.6 Retrieving an Application

5.1.7. Risk Assessment

5.1.8 Programmatic Review

5.1.9 Completing the Review Process

5.1.10 Tracking Application Status

5.2 Award Phase

5.2.1 Notifying Award Recipient

5.2.2 Awarding Grant

5.3 Post Award Phase

5.3.1 Support and Oversight

5.3.2 Obligation of Funds

5.3.3 Reporting Progress

5.3.4 Reimbursement of Expenditures

5.3.5 Post-Award Adjustments

5.3.6 Award Closeout

APPENDIX C – Recipient Financial System Requirements APPENDIX D – Matching Information APPENDIX E – Categories of Expenditures APPENDIX F – Subrecipient Management and Monitoring APPENDIX G – Procurement Standards APPENDIX H – Property Standards APPENDIX I – Sample Application APPENDIX J – Indirect Costs

I. Introduction

The Hazardous Materials Emergency Preparedness (HMEP) Grant Guide provides information on grant management processes and compliance needed to successfully manage HMEP Grant funds. It is designed to reduce risk and error, while increasing efficiencies to help grantees effectively administer their programs.

The HMEP Grant Guide is produced by the United States Department of Transportation (USDOT), Pipeline and Hazardous Materials Safety Agency (PHMSA). PHMSA's mission is to protect people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential to our daily lives. The agency produces the Emergency Response Guidebook (ERG), establishes national policy, sets and enforces standards, educates, and conducts research to prevent incidents.

PHMSA collects registration fees from HAZMAT shippers and carriers. Those fees are then redistributed by PHMSA through several grant programs to include: The Hazardous Materials Emergency Preparedness (HMEP) Grant; Assistance for Local Emergency Response Training (ALERT) Grant; Hazardous Materials Instructor Training (HMIT); Supplemental Public Sector Training (SPST) Grant; and Community Safety (CS) Grant.

II. HMEP Grant Overview

The HMEP grant program was established under The Hazardous Materials Transportation Uniform Safety Act of 1990 (P.L. 101-615), to assist States, Territories, and Native American Tribes to "develop, improve, and carry out emergency plans" within the National Response System and the Emergency Planning and Community Right-To-Know Act of 1986 (EPCA). This includes awarding grants for planning and training activities related to HAZMAT incidents in commercial transportation.

This grant does not fund operational expenditures.

The HMEP grant program is designed to allow grantees the flexibility to implement training and planning programs that address differing needs for each location based on demographics, emergency response capabilities, commodity flow studies, and hazard analysis. Relevant trainings are found in the National Fire Protection Association (NFPA) 472: Standard for Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents publication and the Occupational Safety and Health Administration (OSHA) regulations found in

29 CFR § 1910.120.

Planning efforts fall under the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 (Title 42 U.S.C. Chapter 116), Emergency Planning (301-303). This includes three sections and provisions intended to help communities prepare for chemical emergencies:

• 301 - State and Tribal Emergency Response Commissions (SERCS and TERCs) and Local and Tribal Emergency Planning Committees (LEPCs and TECs)

• 302 - Regulated Substances and Facilities; Emergency Planning Notification), and

• 303 - Comprehensive Emergency Response Plans

Training efforts must be directed towards public sector HAZMAT emergency response employee’s ability to respond to accidents and incidents involving HAZMAT in commercial transportation. This may also include course evaluation to determine effectiveness of delivery and student retention. HMEP training must adhere to either the requirements set forth by the National Fire Protection Association (NFPA) 472 or Occupational Safety and Health Administration (OSHA) 29 CFR § 1910.120 Competencies.

The following sections in this document provide listed reference examples of what a grantee can do to support planning and training efforts.

III. Expenditure Guidelines

This section provides direct examples of allowable, generally unallowable, and conditionally allowable activities. These examples are for reference only.

4.1 Allowable Management and Administration Costs (M&A)

M&A costs (sometimes referred to as general expenditures) are allowable administrative expenditures incurred during the administration of an award and that do not fall under preparedness or response efforts. These must be directly related to the management and administration of the HMEP grant award. This includes but is not limited to: Grants Management Courses, Continuing Education Specific to Grants Management

4.2 Allowable Planning and Preparedness Activities

ALLOWABLE PLANNING AND PREPAREDNESS ACTIVITIES

This list is not all inclusive

Activity Description and Summary Additional Guidance and Materials Commodity Flow Studies

A hazardous materials commodity flow survey (HMCFS) identifies HAZMAT transported into, out of, within, and through a specified area.

PHMSA published document, “Hazardous Materials Commodity Flow Data and Analysis” and EPA’s Sample Commodity Flow Studies https://www.epa.gov/epcra/sample-commodity-flow-studies

Other Commodity Flow Study Related Costs

Example: Aerial photography for use with Commodity Flow Study research using drones.

Expenses must be HMEP related and only charged to the HMEP grant at the rate of use for this program.

https://www.epa.gov/epcra/sample-commodity-flow-studies https://www.epa.gov/epcra/sample-commodity-flow-studies

ALLOWABLE PLANNING AND PREPAREDNESS ACTIVITIES

This list is not all inclusive

Tier II Chemical Inventory Reports and Databases expenses tied to a commodity flow study.

HMEP does not pay for operational costs.

GAP Analysis/Needs Assessment Costs

A needs assessment is the process to determine existing gaps between current conditions and desired conditions.

HMEP Sample Application, Page 6 https://www.phmsa.dot.gov/working -phmsa/grants/hmep-sample-application

EPCRA Compliance Costs. Section 301

State and Tribal Emergency Response Commissions (SERCS and TERCs) and Local and Tribal Emergency Planning Committees (LEPCs and TEPCs)

Per EPCRA 301, Local or Tribal Emergency Planning Committees (LEPCs or TEPCs) must develop an emergency response plan, review the plan at least annually, and provide information about chemicals in the community to citizens.

Refer to Appendix B Resources for additional EPCRA information and EPCRA Compliance Costs Section 301 (cont.) for a breakdown of the required elements of a community emergency response plan.

EPCRA Compliance Costs. Section 301 (cont.)

This list is not all inclusive

• Identification of facilities and transportation routes of extremely hazardous substances.

• Description of emergency response procedures, on and off site.

• Outline of emergency notification procedures.

• Outline of evacuation plans.

• A training program for emergency responders (including schedules).

• Methods and schedules for exercising emergency response plans.

Full list of required elements of a community emergency response plan can be found from the Environmental Protection Agency

(EPA)

https://www.epa.gov/epcra/local-emergency-planning-committees#Local%20Emergency% 20Planning%20Committee%20Reso urces https://www.phmsa.dot.gov/working-phmsa/grants/hmep-sample-application

ALLOWABLE PLANNING AND PREPAREDNESS ACTIVITIES

This list is not all inclusive

EPCRA Compliance Costs. Section 302

Emergency Planning Notification

HMEP funds must be used for the benefit of the first responder.

The HMEP grant may cover costs associated with incorporation information derived from EPCRA 302 requirements into their Emergency Operations Plan

(EOP).

Refer to EPCRA Section 302:

Emergency Planning notification https://www.epa.gov/system/files/do cuments/2022-01/chapter-2-epcra-section-302.pdf

EPCRA Compliance Costs. Section 303.

Comprehensive Emergency Response Plans Local and Tribal Emergency Planning Committee (LEPC and TEPC) Responsibilities Facility Responsibilities State and Tribal Emergency Response Commission (SERC and TERC) Responsibilities

Costs include, but are not limited to:

• LEPCs/TEPCs developing and maintaining comprehensive emergency response plans and submitting these plans to the State or Tribal Emergency Response Commission.

• LEPCs/TEPCs to review the plans annually, or more frequently as circumstances change within the community or at any facility.

All plans should contain:

• Analysis of the emergencies likely to occur.

• Assessment of available resources and existing capabilities.

• HAZMAT Planning Curriculum response operations strategies and assignments that address notification, command and control, life safety, and other functional requirements; and identification of prevention measures that can mitigate the seriousness of an emergency or prevent it from occurring.

See: Appendix B - Resources Conference Attendance and/or Hosting Costs for Emergency Planners

HMEP may fund costs associated with conference attendance as they relate allowable HMEP grant activities.

See: 4.2 Allowable Planning and Preparedness Conferences for a list of examples

HMEP Planning Program Manager Personnel Costs

Only include compensation paid for employees engaged in HMEP grant related activities.

Costs should be consistent with that paid for similar types of work within the organization.

Grantees must meet the grants pass-through requirement: 75% of the total award must be to the direct benefit of the first responder. No more than 25% of a total grant award may be attributable towards M&A costs.

See: HMEP Sample Application, https://www.epa.gov/system/files/documents/2022-01/chapter-2-epcra-section-302.pdf https://www.epa.gov/system/files/documents/2022-01/chapter-2-epcra-section-302.pdf https://www.epa.gov/system/files/documents/2022-01/chapter-2-epcra-section-302.pdf

ALLOWABLE PLANNING AND PREPAREDNESS ACTIVITIES

This list is not all inclusive https://www.phmsa.dot.gov/working -phmsa/grants/hmep-sample-application

Attending and/or Hosting Workshops, Drills and Exercises

Events must be related to allowable HMEP grant activities and have a connection to HAZMAT in commercial transportation

HMEP Sample Application, budget narrative https://www.phmsa.dot.gov/working -phmsa/grants/hmep-sample-application

Capability Assessments

Evaluate the ability for first responders, non-governmental organizations, and other involved stakeholders to respond to a HAZMAT emergency

Hazardous Materials Incident Response Curriculum Guidelines https://www.phmsa.dot.gov/grants/h azmat/response-guidelines Mission Specific Planning Competencies: Capability Assessment. Page 49

Risk Assessments to Enhance Plans

A risk assessment is a process to identify potential hazards and analyze what could happen if a hazard occurs.

Comprehensive Preparedness Guide 201: Threat and Hazard Identification and Risk Assessment Guide (FEMA CPG 201). Example:

https://www.phmsa.dot.gov/hazmat/r eports/risk-assessment-hazmat-uavs

Computer-Aided Management of Emergency Operations (CAMEO) Training

Training towards the usage of

CAMEO

Developed by EPA and the National Oceanic and Atmospheric Administration to assist front-line chemical emergency planners and responders, CAMEO can access, store, and evaluate information critical for developing emergency plans.

4.3 Allowable Training Courses

ALLOWABLE TRAINING COURSES

This list is not all inclusive

Air Monitoring and Sampling HAZMAT IQ Training (Above and Below the line, Advanced IQ & ToxMedic, etc.)

Airport Rescue Fire Fighting (aircraft rescue and response)

HAZMAT Risk Analysis Courses

Alternative Fuels Hazardous Waste Operations and Emergency Response Standard (HAZWOPER)

Ammonia, Ethanol, Chlorine Response Industrial Fire Fighting (rail yards, fuel transfer facilities, and ports) https://www.phmsa.dot.gov/working-phmsa/grants/hmep-sample-application https://www.phmsa.dot.gov/working-phmsa/grants/hmep-sample-application https://www.phmsa.dot.gov/working-phmsa/grants/hmep-sample-application https://www.phmsa.dot.gov/working-phmsa/grants/hmep-sample-application https://www.phmsa.dot.gov/working-phmsa/grants/hmep-sample-application https://www.phmsa.dot.gov/working-phmsa/grants/hmep-sample-application https://www.phmsa.dot.gov/grants/hazmat/response-guidelines https://www.phmsa.dot.gov/grants/hazmat/response-guidelines https://www.phmsa.dot.gov/hazmat/reports/risk-assessment-hazmat-uavs https://www.phmsa.dot.gov/hazmat/reports/risk-assessment-hazmat-uavs

ALLOWABLE TRAINING COURSES

This list is not all inclusive

Cargo Tank Specialty Intermodal Tank Specialty Chemistry of Hazmat-Part I/II Level A/Level B Personal Protective Commodity Flow Study courses Liquid Natural Gas (LNG) rail training Confined Space Rescue LP Gas Emergencies/Propane Emerge Courses aimed at developing, improving, and implementing emergency plans under the Emergency Planning and Community Right-to-Know Act (EPCRA) §§ 301 and 303 (Title 42 U.S.C. Chapter 116)

Lithium Ion-Battery training related to incidents in commercial transportation

Crude Oil Training Marine Operations - Ship-board rescue, firefighting, HAZMAT focus

Decontamination: Mass, Technical, Refresher

Marine Tank Vessel Specialty

Developing Chemistry for Emergency Responders

NIMS ICS-100: Introduction to the Incident Command System

Emergency Medical Technician (EMT) Training for HAZMAT

NIMS ICS-200: Incident Command System for Single Resources and Initial Action Incidents

Employee HAZMAT Emergency Response Readiness Training

NIMS ICS-300: Intermediate Incident Command System

Explosive Ordinance Disposal involving transportation

NIMS ICS-400: Advanced Incident Command System

First Receiver Awareness Training Pipeline Incident in Transportation Response Training

Flammable Liquid Bulk Storage Radiological (sources in transportation, but not Weapons of Mass Destruction.)

Flammable Gas Bulk Storage Regional Response Strategy Selection courses Grants Management Training, Courses, and continuing education

Rope Rescue (pre-requisite for Confined Space Rescue)

HAM Radio Training Surveying a HAZMAT Incident HAZ-CAT Training Tactical Chemistry Cargo Tank Specialty Tank Specialty: Car, Cargo, Marine Vessel, Intermodal HAZMAT Awareness, Operations, Technician, Specialist, and Refresher Courses

TRANSCAER Training as it relates to HMEP

HAZMAT Basic Life Support/Advance Life Support

Using Personal Protective Equipment

HAZMAT Containers Victim Rescue/Recovery HAZMAT for Dispatcher Financial Management courses with Grants

Management correlation HAZMAT for Emergency Management System (EMS)

Victim Rescue/Recovery

4.4 Allowable Planning and Training Preparedness Conferences

Costs associated with attending conferences are allowed. When requesting these costs grantees must state what projects, goals, and deliverables the events support. For example, attendance to a planning conference where the HMEP Grant manager participates in Tabletop Exercises (TTX) will provide lessons learned that the HMEP Grant manager can apply when performing the annual Emergency Operations Plan (EOP) update and review for they LEPCs/TEPCs.

ALLOWABLE PLANNING AND TRAINING PREPAREDNESS CONFERENCES

This list is not all inclusive

Conference Location Website Arizona Tribal Hazardous Materials (HAZMAT) Training and Information Conference

Flagstaff, AZ http://itcaonline.com

International Hazardous Materials Response Teams Conference (IAFC)

Baltimore, MD https://www.iafc.org/

PHMSA HMEP Conference Varies https://www.phmsa.dot.gov/grants /hazmat/hmep-resources

Virginia Hazardous Materials Conference

Harrisonburg, VA http://www.virginiahazmat.org

The Continuing Challenge Sacramento, CA http://www.hazmat.org National Association of SARA Title III Program Officials Annual and Mid-Year and Annual Conference

Houston, TX (mid-year), Varies (annual) https://nasttpo.com/

HOTZONE Houston, TX https://hotzone.mobi/ COLDZONE Minneapolis, MN http://coldzone.org/ Midwest HAZMAT Conference Northbrook, IL https://emerysafety.com/ Northwest Tribal Emergency Management Council (NWTEMC) Annual Conference

Spokane, WA http://nwtemc.org/Conferences_N WTEMC.aspx

TRANSCAER Conferences and Events

Varies http://www.transcaer.com/

4.5 Allowable Equipment, Supplies, and Materials

Equipment, materials and supplies necessary to conduct HMEP planning, and training related activities are allowable. The list below provides examples of previously approved items.

ALLOWABLE EQUIPMENT, SUPPLIES AND MATERIALS

This list is not all inclusive

Airline connection Oxygen meter Aerial Photography Equipment for Commodity Flow Studies/Exercises/Training – usage must be entirely HMEP or charged to HMEP by proportion of HMEP use

Passive dosimeters

Bottom outlet valve Personal Protective Equipment (PPE) Carbon monoxide meter pH indicators and/or pH meters http://itcaonline.com/ https://www.iafc.org/ https://www.phmsa.dot.gov/grants/hazmat/hmep-resources https://www.phmsa.dot.gov/grants/hazmat/hmep-resources http://www.virginiahazmat.org/ http://www.hazmat.org/ https://nasttpo.com/ https://hotzone.mobi/ http://coldzone.org/ http://nwtemc.org/Conferences_NWTEMC.aspx http://nwtemc.org/Conferences_NWTEMC.aspx http://www.transcaer.com/

ALLOWABLE EQUIPMENT, SUPPLIES AND MATERIALS

This list is not all inclusive

Colorimetric tubes Portable pumps (air, electrical, gasoline/diesel

Combustible gas indicator Power-take-off (PTO) driven pumps Compressors or compressed gas Pressure gauge Computing Devices - machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or “peripherals”) for printing, transmitting, and receiving, or storing electronic information

Publication materials

Equipment Trailer Sample valve Gauging device Self-Contained Breathing Apparatus

(SCBA)

General Purpose Equipment Simulators for HAZMAT Training and

Exercise HAZMAT Suits Thermometer Information Technology Systems computing devices, ancillary equipment, software, firmware, and similar procedures, services (including support services), and related resources.

Training trailer

Inventory management system Vacuum trucks Liquid or vapor valve Vehicle not for operational usage (i.e., required to tow training trailers and to carry out planning related activities such as a vehicle for a HAZMAT planner solely dedicated to the HMEP Grant that travels to local emergency responders to carry out the duties to meet EPCRA requirements)

Office supplies related to HMEP activities Foam for specific HAZMAT transportation related planning and training related activities

Equipment is tangible personal property (including information technology systems) having a useful life of more than one year and costs more than $5,000 per item.

Supplies are all tangible personal property other than those described in the definition of equipment and cost less than $5,000 per item.

A computing device is a supply if the acquisition cost is less than the lesser of the capitalization level established by the non-Federal entity for financial statement purposes or $5,000, regardless of the length of its useful life.

Refer to Appendix A – Definitions and Appendix E – Category of expenditures for additional details.

4.5 Conditionally Allowable Expenditures

Conditionally allowable expenditures are expenditures that are generally allowable but require additional or specific conditions.

CONDITIONALLY ALLOWABLE EXPENDITURES

This list is not all inclusive

Expenditure Conditions Tier II Chemical Inventory Reports and Databases

Allowable: Duties and costs related to planning and training for the benefit of first responders, i.e., information gathering for a commodity flow study. CAMEO. See below.

Unallowable: Operational costs.

Note: Information Systems/Computing devises related to Tier II reporting may be considered allowable in full or in part with PHMSA approval See Appendix A - Definitions for Tier II Inventory Reports and Databases more information.

Emergency Operating Center (EOC) Leadership Exercises

Leadership exercises for events concerning HAZMAT preparedness and responses

Hospital Drills Decontamination from a transportation incident (radiological, chemical, or other HAZMAT)

LEPC Meeting Expenses HMEP covers the portion of costs as related to EPCRA Sections 301-303

Food and Refreshments Food must be necessary for the safety of participants, i.e., hydration, remote location, dietary necessities, cultural accommodations etc.

Fixed-facility HAZMAT preparedness Exercises and plans that include transportation of materials to and from fixed facilities; exercises that test the same capabilities that would be used to respond to a HAZMAT transportation incident

Fire Department Instructors Conference

(FDIC)

Transportation HAZMAT-themed schedule

4.5.1 Costs Requiring Prior Approval

Conditionally allowable expenditures may also include costs requiring prior approval the table below includes examples of when a grantee needs to do so.

COSTS REQUIRING PRIOR APPROVAL

This list is not all inclusive

Cost Type Cost Description and Information Sole Source Approval

A request to enter a non-competitive contractual relationship for equipment, technology, or services more than the simplified acquisition threshold must be

COSTS REQUIRING PRIOR APPROVAL

This list is not all inclusive submitted to PHMSA in writing certifying that the award of a contract through full and open competition is infeasible.

Prior Approval of Certain Costs

Written prior approval must be obtained for some costs, as specified in 2 C.F.R.

Part 200 (specifically in 2 C.F.R.§ 200.407). The following are some examples of costs that require prior approval:

• Costs incurred prior to the date of the subaward period

• Foreign travel (only applicable to territories)

Changes to the Scope of the Award

Recipients must initiate an Activity Request (AR) for changes in scope, duration, activities, or other significant areas. In general, a change in scope is a cost that is 10% of the total award or more.

These changes include but are not limited to:

• Altering programmatic activities

• Changing the purpose of the project

• Changing the project site

• Experiencing or making changes to the organization or staff with primary responsibility for implementation of the award, contracting out, subawarding (if authorized by law), or otherwise obtaining the services of a third party to perform activities which are central to the purpose of the award

• Changes in scope that affect the budget Equipment and Other Capital Expenditures

If recipients or subrecipients have received prior approval for expenditures for equipment and other capital assets, including repairs which materially increase the useful life of equipment, then these expenditures are allowable. See 2 C.F.R. § 200.439.

Expenditures for equipment must be fully justified in the budget and budget narrative; otherwise, the grant- making component may require that the type, quantity estimated, unit, or other information be provided before the final budget can be issued.

In reviewing equipment acquisition budgets and proposals, the following principles should be followed:

• No other equipment owned by the recipient/subrecipient is suitable for the project.

• No luxury vehicles will be approved.

If the vehicle request is approved, the vehicle should be reasonable, and the recipients must follow the Internal Revenue Service guidelines.

If the vehicle(s) was purchased as part of a unit of government fleet by the State or local central procurement activities, it is generally accepted as reasonable.

• Federal funds are not used to provide reimbursement for the purchase of equipment already owned by the recipient/subrecipient.

• Equipment purchased and used commonly for two or more programs should be appropriately divided among each activity.

COSTS REQUIRING PRIOR APPROVAL

This list is not all inclusive

• An expenditure for equipment purchased for a common pool is generally allowable as a charge to the award at cost value.

• Equipment that has already been purchased and charged to other activities of the organization is not an allowable expense to the award.

4.6 Unallowable Expenditures

Unallowable expenditures are costs which may never be used with HMEP Grant funding dollars.

Examples of generally unallowable expenses include but are not limited to the below.

GENERALLY UNALLOWABLE EXPENDITURES

This list is not all inclusive

Active Shooter Training FRI (Fire Rescue International): Fire Rescue International (FRI) annual conference for fire and emergency service leaders from across North America and around the globe for 5 days of networking, learning, and collaboration

Alcohol Joint Terrorism Task Force (JTTK) Exercises All-Hazards Warning System Drills Lobbying Any costs disallowable or stated as ineligible in 49 CFR part 110 and 2 CFR 200 Subpart E

Mobile Meth Lab Training

Any cost specifically prohibited in the General Terms and Conditions of the grant award, or identified in PHMSA policy guidance, or as a Special Terms and Conditions listed on the NGA (Remarks section).

Natural Disaster Exercises without a commercial transportation in HAZMAT tie-in

Bonuses or Commissions See 2 C.F.R. § 200.430(g)

Operational Expenses

Corporate Formation Pro Board® accreditation and certification Courses not related to HAZMAT emergency response (except for the pipeline training listed in section 4.1 above)

School Violence Prevention

Emergency Preparedness Presentation to Child Care Providers

State and Local Sales Taxes

Entertainment Costs Tips Fines and Penalties Weapons of Mass Destruction (WMD)

Radiological Training and Terrorism courses

Unallowable expenditures and disallowed costs are costs prohibited by law or regulation, Federal cost principles, PHMSA policy, or special terms and condition of award. Disallowed costs are charges to a federal award that the Federal awarding agency or pass-through entity determines to be unallowable, in accordance with the applicable Federal statutes, regulations, or the terms and conditions of the Federal award (2 CFR 200.31)

IV. Grant Lifecycle

The grant lifecycle timeline previews the overall steps and process of a grant. There are three phases. Each phase has steps, responsible parties, and required actions. This section provides an overview of the grants management process and lifecycle in three phases: Pre-Award, Award Phase, Post Award.

5.1 Pre-Award Phase

The pre-award phase occurs before a grant is awarded.

Lifecycle Steps Responsible Party

Actions

Planning an Opportunity PHMSA Plan and develop funding priorities based on the mission, the Administration, and congressional initiatives.

Announcing an Opportunity PHMSA Formally announce the availability of funds and publish details on grants.gov

Searching for Opportunities Applicant Search for CFDA 20.703 on grants.gov and stay up to date with announcements

Registering on grants.gov Applicant Regularly check grants.gov for funding opportunities and requirements.

Completing an application Applicant Allow for enough time to complete an application. Download the application and save offline. Submit prior to the closing date and time.

Retrieving the application Applicant Applicant will be notified of receipt via e-mail when completed. PHMSA beings review of application.

Staying in the Loop Applicant Applicants can track the status of their application by communicating with the grant-making agency. The application status process is handled differently by each agency.

Finishing the review process PHMSA As the funding agency reviews applications, a range of program stakeholders will participate.

The review process takes time and varies based on grant type. As the review process takes place, grant-making agencies may update applicants on the status of their application.

5.1.1 Planning an Opportunity

The Department of Transportation (DOT) makes awards for a specified period, referred to as the award or project period. The award period is established for each award and is included in the

Notice of Grant Award (NGA) document. Award periods range from 1 year for tribes up to 3 years for states and territories. The performance periods may vary depending on the specific program, and if there are extensions necessary.

Local and Tribal Emergency Planning Committees (LEPCs and TEPCs) are responsible for developing and maintaining comprehensive emergency response plans and submitting these plans to the State or Tribal Emergency Response Commission (SERC or TERC). Local or Tribal Emergency Planning Committees (LEPCs or TEPCs) should review the plans annually, or more frequently as circumstances change within the community or at any facility.

5.1.2 Announcing an Opportunity

PHMSA formally announces the funding opportunity, advertising it to applicant communities and inviting proposals tailored to address the program mission. The grant-making agency will publish details of the funding opportunity on Grants.gov.

5.1.3 Searching for Opportunities

Applicants will use the Grants.gov search tool to find funding opportunities that they are eligible for and are a mission match for their organization. HMEP Funds are announced and issued annually. Applicants are encouraged to e-mail HMEP.Grants@dot.gov to join the grants program contact list.

5.1.4 Registering on Grants.gov

HMEP Grant applicants are required to complete the registration process on grants.gov and sam.gov. System for Award Management (SAM) is the Official U.S. Government system that consolidated the capabilities of the Central Contractor Registration (CCR), Federal Agency Registration (FedReg), the Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS). It became operational in August 2012. Recipients must have registered their Unique Entity ID (UEI) https://www.sam.gov/ portal/SAM/ to receive an award.

Unless exempted from this requirement under 2 CFR § 25.110, the recipient must maintain the information in SAM until the final financial report required under this award is submitted or the Recipient receives the final payment, whichever is later. This requires that the Recipient review and update the information at least annually after the initial registration, and more frequently if required by changes in your information or another award term.

5.1.5 Completing an Application

Completing a grant application can take weeks. The application package can be downloaded from Grants.gov in the form of a PDF, and progress can be saved as form fields are filled in.

These fields require everything from basic organizational information to explanations of mailto:HMEP.Grants@dot.gov proposed work and financial data. When an application package has been completed per the opportunity instructions and checked for errors, it can be submitted through Grants.gov

A sample application can be found in Appendix I Sample Application.

5.1.6 Retrieving an Application

Once an application has been retrieved by the agency from Grants.gov, the applicant is automatically notified via email. At this point, the grantor application processing begins.

5.1.7. Risk Assessment

PHMSA is required to review and assess the potential risks presented by applicants for Federal grants prior to making an award (2 C.F.R. § 200.205). This includes financial capabilities and past performance in a risk-based approach. PHMSA applicants may be required to complete a questionnaire and submit it to PHMSA before they can be approved for an award.

It is PHMSA’s goal for each recipient to be successful. Each HMEP Grantee has an assigned Grant Specialist to assist in meeting the needs of each grantee, to include special attention to high-risk grantees providing guidance, technical assistance, and best practices. Each category will be clearly listed in each Notice of Grant Award (NGA) and include details of what conditions apply to each category. Requirements for each status are specific to each grantee.

In general, a recipient may be designated as high-risk if the following conditions are met:

• Is a first time HMEP Grant recipient.

• Has a history of unsatisfactory performance

• Is not financially stable.

• Has a management system that does not meet the standards set forth in 2 C.F.R. Part 200

(Subpart D-Post Federal Award Requirements (Standards for Financial and Program Management)).Recipient has audit reports with recommendation(s) that have been open for more than one year and has not submitted documentation adequate to close the recommendation(s).

• Recipient has not provided a corrective action plan to the DOT, PHMSA within 105 days of transmission of the audit report to the recipient.

• Recipient has audit reports with questioned costs more than $500,000 (regardless of the amount of time the audit report has been open).

• Recipient has been referred to the Department of Treasury for collection because of their failure to timely repay funds.

If a high-risk grantee does not comply with additional conditions imposed or fails to make timely progress in addressing the issues that resulted in the high-risk designation, PHMSA must consider farther action.

5.1.8 Programmatic Review

PHMSA will complete a programmatic review of the grant application to ensure that recipients are financially capable and have the financial integrity to administer Federal funds.

As part of this review, PHMSA will take the following steps:

• Perform a cost analysis of the project. Obtain cost breakdowns, verify cost data, evaluate specific elements of cost, and examine data to determine the necessity, reasonableness, allowability, allocability, and appropriateness of the proposed cost.

• Review the current indirect cost rates or rates approved by other Federal agencies.

• Non-Federal entities that have never received a negotiated indirect cost rate, except for those non-Federal entities described in Appendix VII to 2 C.F.R. Part 200—States and Local Government and Indian Tribe Indirect Cost Proposals, may elect to negotiate a rate or, if eligible, charge a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely.

• Determine the adequacy of the accounting system and operations to ensure that Federal funds, if awarded, will be expended in a reasonable manner.

• Non-Federal entities that have not received an award within the past three years may require an additional financial review.

Review the status of any Federal debt that the applicant may have to ensure the debt is not delinquent, and other prescreening information, including checking SAM to ensure the organization is not suspended or debarred from receiving Federal funds.

5.1.9 Completing the Review Process

PHMSA is required to ensure that awards meet certain legislative, regulatory, and administrative requirements. This requires that PHMSA review and assess each application to determine the following:

• The applicant is eligible for the specified program.

• The costs and activities in the application are for allowable, allocable, necessary, and reasonable costs.

• The applicant possesses the responsibility, financial management, fiscal integrity, and financial capability to administer Federal funds adequately and appropriately.

5.1.10 Tracking Application Status

Applicants can track the status of their application by communicating with the grant-making agency. The application status process is handled differently by each agency. Further inquiry can be made by contacting HMEP.Grants@dot.gov.

5.2 Award Phase

The award phase is the Period of Performance listed on award documentation.

Lifecycle Steps Responsible Party

Actions

Notifying the Award Recipient

PHMSA When the review process has been completed, the funding agency notifies the applicants whether they have been awarded a grant. The agency also begins working with the award recipient to finalize the legal

Lifecycle Steps Responsible Party

Actions framework for the funding agreement. Following this, the funds are disbursed.

Beginning the Hard Work

PHMSA After an applicant receives a Notice of Award and the funds have been disbursed, they will begin their project. The award recipient is responsible for meeting the administrative, financial, and programmatic reporting requirements of the award.

5.2.1 Notifying Award Recipient

After PHMSA has completed the application review phase, applicants are notified of the award decision. To accept an award, the applicant must follow the instructions contained in the award notice, and follow the procedures as directed in the award Terms and Conditions (T&C). To decline an award, the applicant must notify PHMSA and follow the directions as indicated.

Funding process:

• Applicant will be notified of the award, approval, and obligation, as described previously.

• Once an award has been accepted, to receive payment of funds obligated in DOT’s accounting system, recipients must follow the special conditions listed in the award document as well as with all reporting requirements.

Upon receipt of the NGA, grantees are expected to review the award document in detail. Pay attention to the project start and end dates as well as the reporting requirements.

All recipients are required to submit Federal Financial Reports (SF-425s or FFRs) as well as performance/progress reports on the due dates as indicated in the Terms & Conditions. Please refer to 5.3.2 REPORTING YOUR PROGRESS for more details.

5.2.2 Awarding Grant

Recipients must meet the administrative, financial, and programmatic reporting requirements of the award. Some of those requirements include but are not limited to the information provided in Appendix C Recipient Financial System Requirements, Appendix D Matching Information, Appendix E Categories of Expenditures, Appendix F Subrecipient Management and Monitoring, Appendix G Procurement Standards, and Appendix H Property Standards.

5.3 Post Award Phase

The post-award phase occurs after the period of performance begins.

Lifecycle Steps Responsible Party

Actions Reference

Providing Support and Oversight

PHMSA Technical assistance, conference calls, site visits, spot checks, desk reviews

Refer to grant award Terms and Conditions

Lifecycle Steps Responsible Party

Actions Reference

Reporting your Progress

Grantee Prepare and submit programmatic and financial reports on a timely basis.

It is expected that programmatic and financial personnel both be aware of the contents of the entire grant award package.

Refer to NGA for specific report types, due dates, and submission requirements.

Programmatic and Financial personnel should receive a copy of the agreement documents and the entire Notice of Grant Award Package to ensure compliance.

https://www.grants.gov/web/gr ants/learn-grants/grants- 101/post-award-phase.html#reporting

Award Closeout PHMSA Upon completing all the closeout requirements, including a review of the final financial and technical reports from the awardee, the grant lifecycle comes to an end.

https://www.grants.gov/web/gr ants/learn-grants/grants- 101/post-award-phase.html#closeout

5.3.1 Support and Oversight

After an award has been disbursed, a grants management officer at PHMSA oversees an awardee's reporting compliance. This process extends across the life of the grant award and involves reviewing reports submitted by the awardees. Representatives from the grantor agency may perform on-site visits with the project director and implementation staff. Oversight may also occur in the form of auditing. PHMSA also conducts quarterly conference calls with recipients as well as monitors the obligation of funds.

5.3.2 Obligation of Funds

An obligation is a binding agreement made during a given period that requires payment during the same or a future period. For example, if an order is placed for a piece of equipment to be purchased with award funds, the order is an obligation. See 2 C.F.R. § 200.71

Obligations must occur during the project period stated on the award document. An obligation occurs when there is a binding agreement, such as in a valid purchase order or requisition, that covers the cost of purchasing an authorized item on or after the begin date and up to the last day of the award period. See 2 C.F.R. § 200.309

Note: Obligations must occur during the project period. If funds are obligated (e.g., enter a contract) prior to the start of the project period, that obligation may not be an allowable expense, https://www.grants.gov/web/grants/learn-grants/grants-101/post-award-phase.html#reporting https://www.grants.gov/web/grants/learn-grants/grants-101/post-award-phase.html#reporting https://www.grants.gov/web/grants/learn-grants/grants-101/post-award-phase.html#reporting https://www.grants.gov/web/grants/learn-grants/grants-101/post-award-phase.html#reporting https://www.grants.gov/web/grants/learn-grants/grants-101/post-award-phase.html#closeout https://www.grants.gov/web/grants/learn-grants/grants-101/post-award-phase.html#closeout https://www.grants.gov/web/grants/learn-grants/grants-101/post-award-phase.html#closeout https://www.grants.gov/web/grants/learn-grants/grants-101/post-award-phase.html#closeout unless the award recipient notifies the awarding agency in advance in writing and receives prior written approval from the awarding agency.

5.3.3 Reporting Progress

Award recipients must report their progress per the Terms and Conditions (T&C) of their Notice of Grant Award (NGA). This includes but is not limited to: Federal Financial Report (FFR) submission, Progress Reports, Reimbursement requests, and post-Award adjustments.

At a minimum, required reporting documentation includes:

• Federal Financial Reports (FFRs) Each Grantee is required to submit Semiannual, Annual, and Final FFRs. Each FFR is cumulative.

• The Final FFR should capture the cumulative obligations and disbursements that have occurred from the initial grant award date through the end date of the performance period.

• Each grantee is required to submit an annual Performance Progress Reports (PPR) and a Final PPR. The Final PPR is a comprehensive report of the entire performance period. It should include all activities that were completed during the entire performance period.

• All Grantees must provide a final SF424A that reflects the combined total for all three years of funding.

HMEP Grant recipients are required to submit reimbursement requests (or requests for advancement) to receive payment.

5.3.4 Reimbursement of Expenditures

Recipients are required to request, obtain, and maintain an active account in the accounting system used for reimbursement of HMEP funds within Delphi E-Invoicing.

https://einvoice.esc.gov/ E-mail HMEP.Grants@dot.gov to request account access. Recipients are expected and required to request reimbursement for expenditures in a reasonable and timely manner.

Requests for reimbursement must include a SF-270 that can be accessed online via the Delphi eInvoicing System or uploaded if the online SF-270 is not operational. Grantees are also required to submit supporting documentation for payment requests. PHMSA may request additional substantiation for supporting reimbursement payments at any time. A lack of supporting documentation on file may result in questioned or unallowable costs. PHMSA will not approve reimbursement requests for unapproved activities.

Funds should be requested based on immediate disbursement and reimbursement requirements.

Funds will not be paid in a lump sum, but rather disbursed over time as project costs are incurred or anticipated.

Draw down requests should be timed to ensure that Federal cash on hand is the minimum needed for disbursements and reimbursements to be made immediately or within 10 days. If not spent or disbursed within 10 days, funds must be returned to PHMSA.

https://einvoice.esc.gov/

Fund requests from subrecipients create a continuing cash demand on award balances of the recipient. Recipients should keep in mind that idle funds in the hands of subrecipients will impair the goals of effective cash management.

Recipients must have written procedures for cash management of funds to ensure that Federal cash on hand is kept at or near zero.

5.3.5 Post-Award Adjustments

Project changes are budget modifications and award recipients must request an activity request to make a programmatic, administrative, or adjustment through the PHMSA Agency Portal for budget modification if:

• The proposed cumulative change is greater than 10% of the total award amount. The 10% rule does not apply to an award of less than $250,000 (increased from $150,000).

• The budget modification changes the scope of the project. Examples include altering the purpose of the project, authorizing use of a subcontractor or other organization that was not identified in the original approved budget, or contracting for or transferring of award-supported efforts.

• A budget adjustment affects a cost category that was not included in the original budget.

For example, if the direct cost category “Travel” did not exist in the original budget, the adjustment to transfer funds from Equipment to Travel requires an activity request.

5.3.6 Award Closeout

All obligations properly incurred by the end of the Federal award must be liquidated no later than 120-days after the end date of the award. If the award has been properly obligated, the full liquidation period is available for remaining expenditures. Any funds not liquidated at the end of the 120-day period may revert to the awarding agency.

The liquidation period exists to allow projects time to receive ordered goods and make final payments.

No new obligations may be made during the liquidation period.

As reports and financial data are passed along to the grantor agency, the program stakeholders ensure that all requirements are being met. Upon completing all the closeout requirements, including a review of the final financial and technical reports from the awardee, the grant lifecycle comes to an end.

Award recipients will receive a formal close out letter from PHMSA.

APPENDIX A - Definitions

TERM DEFINITIONS as per 2 CFR 200 and 49 CFR 107 Acquisition cost The cost of the asset including the cost to ready the asset for its intended use. Acquisition cost for equipment, for example, means the net invoice price of the equipment, including the cost of any modifications, attachments, accessories, or auxiliary apparatus necessary to make it usable for the purpose for which it is acquired. Acquisition costs for software includes those development costs capitalized in accordance with generally accepted accounting principles (GAAP). Ancillary charges, such as taxes, duty, protective in transit insurance, freight, and installation may be included in or excluded from the acquisition cost in accordance with the non-Federal entity's regular accounting practices.

Advance payment

A payment that a federal awarding agency or pass-through entity makes by any appropriate payment mechanism, including a predetermined payment schedule, before the non-Federal entity disburses the funds for program purposes.

Allocation The process of assigning a cost, or a group of costs, to one or more cost objective(s), in reasonable proportion to the benefit provided or other equitable relationship. The process may entail assigning a cost(s) directly to a final cost objective or through one or more intermediate cost objectives.

Budget The financial plan for the Federal award that the Federal awarding agency or pass-through entity approves during the Federal award process or in subsequent amendments to the Federal award. It may include the Federal and non-Federal share or only the Federal share, as determined by the Federal awarding agency or pass-through entity.

Budget period The time interval from the start date of a funded portion of an award to the end date of that funded portion during which recipients are authorized to expend the funds awarded, including any funds carried forward or other revisions pursuant to 2 CFR 200.308.

Budget The financial plan for the project or program that the Federal awarding agency or pass-through entity approves during the Federal award process or in subsequent amendments to the Federal award. It may include the Federal and non-Federal share or only the Federal share, as determined by the Federal awarding agency or pass-through entity.

Capital Assets Tangible or intangible assets used in operations having a useful life of more than one year which are capitalized in accordance with GAAP tangible or intangible assets used in operations having a useful life of more than one year which are capitalized in accordance with GAAP. Capital assets include:

(a) Land, buildings (facilities), equipment, and intellectual property (including software) whether acquired by purchase, construction, manufacture, lease-purchase, exchange, or through capital leases; and

(b) Additions, improvements, modifications, replacements, rearrangements, reinstallations, renovations or alterations to capital assets that materially increase their value or useful life (not ordinary repairs and maintenance).

TERM DEFINITIONS as per 2 CFR 200 and 49 CFR 107 Capital expenditures

Expenditures to acquire capital assets or expenditures to make additions, improvements, modifications, replacements, rearrangements, reinstallations, renovations, or alterations to capital assets that materially increase their value or useful life

Catalog of Federal Domestic Assistance

(CFDA)

number

The title of the program under which the Federal award was funded in the

CFDA.

Closeout The process by which the Federal…