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Federal Emergency Management Agency
To report suspected fraud, waste, or abuse, please call
FEMA's hotline at 1-800-323-8603.
Disaster recovery assistance is available without regard to race,
color, national origin, sex, age, religion, disability, or economic
status. Anyone who believes he/she has been discriminated
against should contact the FEMA Helpline at 1-800-525-0321.
Small Project Validation
Chapter 5
Small Project Validation
What is Small Project Validation?
A distinctive aspect of small project approval is the verification of
the accuracy of your claims by FEMA and/or State officials
through a process called validation. This process assures FEMA
that you understand the documentation and eligibility provisions
of the Public Assistance
Program and that you are
capturing all eligible costs.
Your records are the basis for
validation, which will be
limited to the minimum
amount of review needed to
ensure statutory and regulatory compliance.
• This will normally be 20%, barring significant discrepancies,
of all your small projects, for projects submitted within the
first 30 days after the Kickoff Meeting. Normally, projects
submitted after 30 days will be subject to 100% validation.
• Your PAC will schedule validation at a time convenient for
you, and you will be notified in advance which projects have
been selected. This will allow you to have the appropriate
records ready for review.
• Validation can normally be completed within 15 days of
submission of all Project Worksheets to the PAC.
How does it work?
The validation process begins when your Project Worksheets are
submitted to the PAC. The PAC will review each worksheet to
ensure the scope of work is complete and that all Special
Considerations have been identified. Once you have determined
that all small projects have been submitted, or a large batch of
projects has been submitted, you should notify the PAC to
proceed with validation. The PAC will request a Specialist from
the FEMA I State resource pool to conduct the validation. The
Federal Emergency Management Agency 41
Applicant Handbook
Small Project Validation
PAC, with input from the State, will select two samples from all
the small projects you have submitted. Each sample is made up
of 20% of the total small projects. If the first sample does not
pass validation, the Specialist will conduct a second validation
using the remaining sample. If an applicant has 4 or fewer
Project Worksheets, a minimum of 1 Project Worksheet will
always be validated.
What will the Specialist be looking for?
A Specialist will be assigned to conduct the validation and will
perform the following tasks:
• Visit the sites to confirm all aspects of
the project description are accurate,
complete and that all Special Considerations
have been identified.
• Confirm the damage description is
complete, accurate and eligible.
• Confirm the scope of work is complete,
accurate and eligible.
• Review all actual cost records to ensure
completeness, accuracy and eligibility.
• Review your cost estimate to ensure it
is complete, accurate, reasonable and eligible.
These tasks will require the Specialist to review the project
file including all cost records, computations,
measurements, notes, pictures, blueprints, plans,
environmental conditions, Special Considerations, and any
other documentation related to the project. You are
responsible for documenting all claimed costs. This is a
critical responsibility since undocumented costs could be
considered a variance and potentially put you over the
20% allowable variance. When this happens, the second
20% sample must be validated.
42 Federal Emergency Management Agency
Applicant Handbook
Small Project Validation
What happens during validation?
The Specialist will use a Validation Worksheet (FEMA Form 90-
118) and a Project Validation Form (FEMA Form 90-119) to
record variances on eligibility and costs estimates. A variance is
the difference between the information the applicant has
included in the project and the information that the Specialist
determines to be eligible and reasonable.
• Eligibility differences will occur when the applicant includes
ineligible work in the scope of work or ineligible items in the
components of a project
• Cost estimate variances will occur when the applicant has
made an error in estimating a project cost.
• Variances are recorded as the difference in dollar cost
assigned to the item in question by the applicant and the
dollar cost determined by the Specialist.
The Specialist will note and correct all eligibility and cost
variances, and these changes will be made on the Project
Worksheets. If the total variances on the first sample projects
do not exceed 20% of the cost of the sample projects, the
results of validation are satisfactory. If the results are
satisfactory but minor error patterns are seen the applicant will
be encouraged to review all other projects for similar problems.
After you have made any of these corrections, all small projects
Federal Emergency Management Agency 43
Applicant Handbook
Small Project Validation
without Special Considerations will be approved and funded by
the PAC.
If the results of validation are unsatisfactory, the Specialist will
validate the second sample using the same process. If the total
eligibility and cost variance on all projects does not exceed 20%
of the total cost for all projects in both samples the validation
results are satisfactory. If however, the second sample results
are also unsatisfactory, the PAC will assign a Specialist to assist
you in reformulating and resubmitting all projects. Projects
being reformulated will be obligated as each Project Worksheet
is completed and reviewed by the PAC.
Those small projects with Special Considerations will be
individually funded as the Special Considerations issues are
resolved. All small projects submitted after 30 days from the
Kickoff Meeting may be validated on an individual basis and will
be obligated as each validation is completed.
Will more than the two samples ever be
validated?
Yes. All Project Worksheets submitted later than 30 days from
the Kickoff Meeting may be validated and all variances corrected.
Your PAC can answer any specific questions you may have
concerning validation.
WHAT DO 1 NEED TO KNOW????????
./ If expedited funding is requested, emergency work Project
Worksheets can be processed by the PAC and handled
separately for the purposes of validation .
./ If, during the first 30 days, you submit all small projects at
one time, they will be validated as a group; if you submit
small projects at more than one time, each group may be
validated individually. The choice is yours, based on your
funding or other needs.
44 Federal Emergency Management Agency
Applicant Handbook
Small Project Validation
,/ You are responsible for maintaining all documentation
needed to support the project listed on the Project
Worksheet.
../ Normally, you are not required to submit supporting
documentation to FEMA, but you should retain it for three
(3) years from the date the State closes your grant.
,/ Validation of your small projects will be scheduled so you will
know in advance when and which projects will be validated.
This will give you the opportunity to have all pertinent
records ready for review and expedite the validation process .
../ Review the following Validation Worksheet to become
familiar with what the Specialist will be looking for during
the validation process.
Federal Emergency Management Agency 45
Applicant Handbook
Small Project Validation
Validation Worksheet
1_,.
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0 EHglble
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0 FEMAratauMd
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0 Calculatlona
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0 Purchase order$/lnvolces
0 Inventory rec:ordslatock tickets
0 Colculotlon>
RMA Fonntl-1'11. NOV M
46 Federal Emergency Management Agency
Applicant Handbook
Small Project Validation
Cost estimating mathOd approved by PAC
0 CI!CUiations
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0 Hi<tork:
Federal Emergency Management Agency 47
Applicant Handbook
