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support select operational
expenses associated with increased security measures at critical infrastructures sites in the following authorized categories:
- Backfill and overtime expenses (as defined in FOA) for staffing State or Major Urban Area fusion
centers;
- Hiring of contracted security for critical infrastructure sites;
- Public safety overtime (as defined in FOA)
- Title 21 or State Active Duty National Guard deployments to protect critical infrastructure sites,
including all resources that are part of the standard National Guard deployment package); and
- Increased border security activities in coordination with CPB, as outlined in Information Bulletin
135.
FY 2012 SHSP funds may only be spent for operational overtime costs upon prior approval provided in writing by the
FEMA Administrator.
Travel expenses
Meeting-related expenses (For a complete list of allowable meeting-related expenses, please review the OJP
Financial Guide at http://www.ojp.usdoj.gov/FinGuide).
Acquisition of authorized office equipment, including:
Personal computers
Laptop computers
Printers
LCD projectors, and
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Other equipment or software which may be required to support the implementation of the homeland
security strategy
The following are allowable only within the period of performance of the contract:
Recurring fees/charges associated with certain equipment, such as cell phones, faxes, etc.
Leasing and/or renting of space for newly hired personnel during the period of performance of the grant program
E. Unauthorized Expenditures
Activities unrelated to the completion and implementation of the grant program
Other items not in accordance with the Authorized Equipment List or previously listed as allowable costs
Funding may not be used to supplant ongoing, routine public safety activities of state and local emergency responders,
and may not be used to hire staff for operational activities or backfill. Funds cannot not replace (supplant) funds that
have been appropriated for the same purpose.
F. Construction and Renovation
Project construction using SHSP and UASI funds may not exceed the greater of $1,000,000 or 15% of the grant award.
For the purposes of the limitations on funding levels, communications towers are not considered construction.
Written approval must be provided by FEMA prior to the use of any HSGP funds for construction or renovation. When
applying for construction funds, including communications towers, at the time of application, grantees are highly
encouraged to submit evidence of approved zoning ordinances, architectural plans, any other locally required planning
permits and documents, and to have completed as many steps as possible for a successful EHP review in support of their
proposal for funding (e.g., completing the FCC’s Section 06 review process for tower construction projects; coordination
with their State Historic Preservation Office to identify potential historic preservation issues and to discuss the potential for
project effects). Projects for which the grantee believes and Environmental Assessment (EA) may be needed, as defined in
44 CFR 10.8 and 10.9, must also be identified to the FEMA Program Analyst within six (6) months of the award and
completed EHP review packets must be submitted no later than 12 months before the end of the Period of Performance.
EHP review packets should be sent by the SAA to FEMA for review.
FEMA is legally required to consider the potential impacts of all HSGP projects on environmental resources and historic
properties. Grantees must comply with all applicable environmental planning and historic preservation (EHP) laws,
regulations, and Executive Orders (EOs) in order to draw down their FY 2012 HSGP grant funds. To avoid unnecessary
delays in starting a project, grantees are encouraged to pay close attention to the reporting requirements for an EHP review.
For more information on FEMA’s EHP requirements please refer to Bulletins 329 and 345
(http://www.fema.gov/government/grant/bulletins/indes.shtm).
FY 2012 HSGP Program grantees using funds for construction projects must comply with the Davis-Bacon Act (40 U.S.C.
3141 et seq.). Grant recipients must ensure that their contractors or subcontractors for construction projects pay workers
employed directly at the work-site no less than the prevailing wages and fringe benefits paid on projects of a similar
character. Additional information, including Department of Labor wage determinations, is available from the following
website: http://www.dol.gov/compliance/laws/comp-dbra,htm.
In addition, the erection of communications towers that are included in a jurisdiction’s interoperable communications plan
is allowed, subject to all applicable laws, regulations, and licensing provisions. Communication tower projects must be
submitted to FEMA for EHP review. Per the Consolidated Security, Disaster Assistance, and Continuing Appropriations
Act of 2009 (Public Law 110-329), communications towers are not subject to the$1,000,000 construction and renovation
cap.
Approval Process:
In order for grantees to drawdown funds for construction and renovation costs, the grantee must provide the Division with:
A description of the asset or facility, asset location, whether the infrastructure is publicly or privately owned, and the
construction or renovation project;
Certification that a facility vulnerability assessment has been conducted
An outline addressing how the construction or renovation project will address the identified vulnerabilities from the
assessment
Consequences of not implementing the construction or renovation project
Any additional information requested by FEMA to ensure compliance with Federal environmental and historic
preservation requirements
Additional information may also be found on the FEMA’s website located at http://www.fema.gov/plan/ehp/.
Note: Written approval must be provided by FEMA prior to the use of any funds for construction or renovation.
G. Overtime and Backfill Guidance
Personnel (SHSP and UASI) – Personnel hiring, overtime, and backfill expenses are permitted under this grant in order to
perform allowable FY 2012 HSGP planning, training, exercise, and equipment activities. A personnel cost cap of up to 50
25
percent (50%) of the total SHSP and UASI program funds may be used for personnel and personnel-related activities as
directed by the Personnel Reimbursement for Intelligence Cooperation and Enhancement (PRICE) of Homeland Security
Act (Public Law 110-412). Grantees who wish to seek a waiver from the personnel cost cap must provide documentation
explaining why the cap should be waived; waiver requests will be considered only under extreme circumstances. In
general, the use of SHSP and UASI funding to pay for staff and/or contractor regular time or overtime/backfill is
considered a personnel cost.
For further details, please refer to Information Bulletin 358.
FY 2012 HSGP funds may not be used to support the hiring of any personnel for the purposes of fulfilling traditional
public health and safety duties or to supplant traditional public health and safety positions and responsibilities.
Definitions for hiring, overtime, and backfill-related overtime, and supplanting remain unchanged from FY 2011 HSGP.
H. National Incident Management System (NIMS) Compliance
HSPD-5, “Management of Domestic Incidents,” mandated the creation of NIMS and the National Response Plan (NRP).
NIMS provides a consistent framework for entities at all jurisdictional levels to work together to manage domestic
incidents, regardless of cause, size, or complexity. To promote interoperability and compatibility among Federal, State,
local, and tribal capabilities, NIMS includes a core set of guidelines, standards, and protocols for command and
management, preparedness, resource management, communications and information management, supporting
technologies, and management and maintenance of NIMS. The NRP, using the template established by NIMS, is an all-
discipline, all-hazards plan that provides the structure and mechanisms to coordinate operations for evolving or potential
Incidents of National Significance, which are major events that “require a coordinated and effective response by an
appropriate combination of Federal, State, local, tribal, private sector, and nongovernmental entities.”
The NIMS Integration Center (NIC) recommends 38 NIMS Compliance Objectives for nongovernmental organizations
that support NIMS implementation. These activities closely parallel the implementation activities that have been required
of State, territorial, tribal, and local governments since 2004 and can be found at
www.fema.gov/pdf/emergency/nims/ngo_fs.pdf. To integrate nonprofit organizations into the broader national
preparedness effort, DHS encourages grantees to consider pursuing these recommended activities.
Additionally, nongovernmental organizations grantees and sub-grantees will be required to meet certain NIMS compliance
requirements. This includes all emergency preparedness, response, and/or security personnel in the organization
participating in the development, implementation, and/or operation of resources and/or activities awarded through this
grant must complete training programs consistent with the NIMS National Standard Curriculum Development Guide.
Minimum training includes IS-700 NIMS: An Introduction. In addition, IS-800.a NRP: An Introduction, Incident
Command System (ICS-100), Incident Command System (ICS-200), Intermediate Incident Command System (G-300), and
Advanced Incident Command System (G-400) are also recommended. For additional guidance on NIMS training, please
refer to http://www.fema.gov/emergency/nims/nims_training.shtm.
Additional information about NIMS implementation and resources for achieving compliance are available through the
NIMS Integration Center (NIC), at http://www.fema.gov/emergency/nims/.
III. Reporting Requirements
1. Quarterly Programmatic Reporting:
The Quarterly Programmatic Report is due within 30 days after the end of the reporting periods (March 30, June
30, September 30 and December 30) for the life of this contract.
If a report(s) is delinquent, future financial reimbursements will be withheld until the Recipient’s
reporting is current.
If a report goes 2 consecutive quarters without Recipient providing information in the narrative
portion of the Quarterly Status Report, Report will be denied until narrative is provided, also
financial reimbursements will be withheld until the required information has been submitted.
Programmatic Reporting Schedule
